--- title: "FOIA Records: Florida (EFTA02857384)" source: "FOIA Records: Florida" sourceUrl: "https://www.justice.gov/epstein/files/Freedom%20of%20Information%20Act%20%28FOIA%29/Florida/EFTA02857384.pdf" date: "2026-08-12" category: "FOIA" eftaNumber: "EFTA02857384" ocrPages: 1 ocrChars: 141790 ocrElapsed: 0.0 parseTier: "internal" engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1" --- # Barbara I | From: | Barbara I | |----------|----------------------------------| | Sent: | Thursday, April 01, 2010 8:49 AM | | То: | 'Jack Goldberger' | | Cc: | Michael McAuliffe | | Subject: | RE: Epstein | I shared your latest email with Mr. McAuliffe and we both agree that it is our position that he needs to honor his commitment and complete his community control as agreed. If you feel it necessary to file a motion to modify or early terminate on behalf of your client just let me know so I can have enough time to get the Det. and victims notified so they can appear for the hearing. Thanks! From: Jack Goldberger [mailto:jgoldberger@agwpa.com] Sent: Wednesday, March 31, 2010 5:03 PM To: Barbara Subject: Epstein #### Barbara It is obvious you have spent a lot of time on my request for my client and I sincerely appreciate the thoroughness and the attention. As my clients case seems to lend itself to misunderstandings and miscommunications by others, I thought it important to clarify some facts assumed in error. I have spoken to Mr. Gaines at probation and he confirmed the following: Yes termination of supervision on a sex offender is unusual, however a modification to probation from Community control is not uncommon when the probationer has been in compliance without violation. In fact the department's current policy on re-entry to the community dictates that an offender be stepped down as soon as possible. He was also under the misimpression, as others might have been, that Epstein's charges called for sex offender probation. They do not, he is eligible for normal probation. As with many of the issues in my clients case, sterile questions that may have been asked tend to lead to answers that though well meaning are not applicable. As for the timeliness of the police reports of the attempted breakins, I wanted you to be aware that I confirmed with Wackenhut that they called the police each time and spoke to the captain on duty, there should be a record. I said to you it was my advice to the client that he not file a formal report. You have suggested that to resolve all the issues my client move to transfer his community control and that your office would support his transfer. I appreciate that and spoke to Mr. Gaines about that and he doesn't believe that would be possible to New York. Mr. Gaines suggested an agreement to allow Mr. Epstein to travel for business purposes without the present 48 hour limitation but strictly at the **discretion and with the approval of probation** for the remaining short portion of his supervision would be appropriate. He advised me that the department would not object to such a modification. This to me is the fairest way to deal with the issues, and to insure Mr. Epstein is treated like others, Let me know and I can prepare some proposed language that I think would work for everyone Jack Goldberger 561-659-8300 Phone 561-835-8691 Fax # In Re: Possible VOP (8/19/09) Please note. Florida has a very broad public records law Most written communications to or from state officials regarding state business are public records available to the pubic and media upon request. Your e-mail communications may therefore be subject to public disclosure. Barbara | From: | Michael McAuliffe | |----------|----------------------------------| | Sent: | Thursday. April 01, 2010 8:31 AM | | To: | Barbara | | Subject: | RE: Epstein | I think, as you suggest, the defendant simply needs to finish his sentence as it was agreed to in the initial resolution. Thanks. MM ----Original Message----From: Barbara Sent: Thursday, April 01, 2010 08:25 AM Eastern Standard Time To: Michael McAuliffe; Paul Zacks Subject: FW: Epstein This dragon just keeps raising its ugly head! May I tell him to just file his motion to modify with the Court? I don't know how to convey to him anymore than I already have that his client is a registered sex offender that was fortunate to get the deal of the century, fortunate enough, even as a sex offender, to be granted work release while serving his jail sentences (I am not aware of that ever happening before) and certainly fortunate to plea at a time when it was not required by statute that he be placed on sex offender probation with all of the restrictive conditions that the vast majority of individuals in his similar situation would have been subjected to. Please advise. From: Jack Goldberger [mailto:jgoldberger@agwpa.com] Sent: Wednesday, March 31, 2010 5:03 PM To: Barbara Subject: Epstein Barbara It is obvious you have spent a lot of time on my request for my client and I sincerely appreciate the thoroughness and the attention. As my clients case seems to lend itself to misunderstandings and miscommunications by others, I thought it important to clarify some facts assumed in error. I have spoken to Mr. Gaines at probation and he confirmed the following: Yes termination of supervision on a sex offender is unusual, however a modification to probation from Community control is not uncommon when the probationer has been in compliance without violation. In fact the department's current policy on re-entry to the community dictates that an offender be stepped down as soon as possible. He was also under the misimpression, as others might have been, that Epstein's charges called for sex offender probation. They do not, he is eligible for normal probation. As with many of the issues in my clients case, sterile questions that may have been asked tend to lead to answers that though well meaning are not applicable. As for the timeliness of the police reports of the attempted breakins, I wanted you to be aware that I confirmed with Wackenhut that they called the police each time and spoke to the captain on duty, there should be a record. I said to you it was my advice to the client that he not file a formal report. You have suggested that to resolve all the issues my client move to transfer his community control and that your office would support his transfer. I appreciate that and spoke to Mr. Gaines about that and he doesn't believe that would be possible to New York. Mr. Gaines suggested an agreement to allow Mr. Epstein to travel for business purposes without the present 48 hour limitation but strictly at the discretion and with the approval of probation for the remaining short portion of his supervision would be appropriate. He advised me that the department would not object to such a modification. This to me is the fairest way to deal with the issues, and to insure Mr. Epstein is treated like others, Let me know and I can prepare some proposed language that I think would work for everyone Jack Goldberger 561-659-8300 Phone 561-835-8691 Fax Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure. PRIVATE ning w family WAckerhut PBPD -Burglary (Mob ??) -MAN in bushes (noth) CAPIER (nothing eptd. E.T. P. None S. 0,'3 from Letter signed AUSA position Letter Black by Slomm. St. Ct. issue (no Fed. interest?) ("strict compliance) Steph. Ofc. Wm's. DOC 5.0. CC JANDBANK DOC Ofe. GAINES Supr. Fri night? (Ast wk. Rptd. A person in dark Chrysler 300. Chased/security. \*\* Got the best deal of anyone. Warned about bracelet if he violates. (Last Sept./Oct.) We did not file chos Against Any co-def/comp's. = (JAMUSZ BARACEL) Public Records Request No. 19-372 ## Barbara From: Barbara Sent: Friday, March 26, 2010 9:02 AM To: Michael McAuliffe Subject: FW: Confidential As per your request I am forwarding the following summary: Re: The Burglary/Attempted Burglary allegations, the Palm Beach PD were surprised to hear this and indicated that there has never been such complaint(s) since Epstein was place on Community Control. I spoke further with Jack Goldberger and he indicated that Epstein employs private security through Wackenhut and they intercepted this person who was dressed in black like a Ninja and hiding in some bushes. They chased him to a dark Chrysler 300 and took down the tag info. From there they were able to find out that it was registered to a PI that has been associated/linked to Atty. Rothstein and the Gambino family. I spoke with DOC Community Control Supervisor, Ofc. Gaines, and he advised me that late last week Epstein informed him of a similar incident. Ofc. Gaines went on to say that he spoke with Epstein in late Sept. or possibly Oct. of last year and explained to him that he received "the best deal ever heard of for someone in his situation" and that he warned him to follow every condition by the letter so as not to get violated. If violated, he could very well be put on an ankle bracelet which would be even more of a restriction to him. Re: Similar defendants on community control and early termination, drawing from my experience (8 ½ yrs. of doing these cases), Daliah Weiss, Chief of SVU, and DOC there is no known case where a Sex Offender on Community Control has ever been given early termination of Community Control by agreement from our office or DOC. There have been **rare** instances where a person who has been on a very long probation has been given early termination of years on probation has been given Re: The position of the U.S. Attorney's office on early termination of the State's case against Epstein, I again spoke with AUSA Villafana and inquired specifically of any knowledge that she had in reference to representations made by her or anyone associated with her office regarding Epstein's efforts to early term his Community Control on the State charges. She indicated that she had not made any such representations however her boss, interim U.S. Atty. Sloman may have. After checking she sent me a portion of the last letter sent to Epstein's attorneys. I have forwarded that to you by attachment. Please let me know if there is anything else that I can provide to you. From: Villafana, Ann C. (USAFLS) [mailto Sent: Thursday, March 25, 2010 4:20 PM To: Barbara Subject: Confidential Hi Barbara – Here is the relevant portion of the last letter to JE's attorneys regarding the termination of supervision: In light of Mr. Acosta's prior statements to Mr. Epstein's counsel that Mr. Epstein would be eligible for any benefit available to other similarly-situated state defendants, the Office agrees that Mr. Epstein may apply for early termination or modification of community control in accordance with Fl. Stat. §§ 948.05 and 948.10(4), assuming that Mr. Epstein has completed "the sanctions imposed in the community control plan." The Office takes no position regarding such an application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his counsel may not make a representation to the State Attorney's Office, the Court, or any victim that the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior erroneous statements in court filings, we respectfully request that a copy of any court filing be provided to our office. If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time, and location of such hearing. The communication will consist merely of a notification and will neither encourage nor discourage attendance or submission of materials related to the application. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 | Phon | | |------|--| | Fax | | Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. Your e-mah communications may therefore be subject to public disclosure. Barbara From: Sloane, Carmen Sent: Wednesday, February 24, 2010 11:41 AM To: Barbara Subject: RE: J. Epstein Yeah – lot less stress From: Barbara [mailto:BBurns@sa15.state.fl.us] Sent: Wednesday, February 24, 2010 11:34 AM To: Sloane, Carmen Subject: RE: J. Epstein Ok, thanks!!! I hope that was a good thing for you! From: Sloane, Carmen [mailto Sent: Wednesday, February 24, 2010 11:32 AM To: Barbara Subject: RE: J. Epstein Hi, His term date is 7-21-2010. I was recently transferred to the downtown office. If you have any further questions, you can contact his new officer Candice Elkins (Community Control Officer at 154 Lake Worth 434-3960). If you have any questions regarding his past supervision, please email or call me a Carmen From: Barbara [mailto Sent: Wednesday, February 24, 2010 11:19 AM To: Sloane, Carmen Subject: J. Epstein Good morning Carmen. I need to know what you have as the termination date of Mr. Epstein's community control. Thanks!!! Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure. ATTERBURY GOLDBERGER & WEISS, P.A. \* R.ATTERBURY \* JASON S.WEISS "Board Certified Criminal Trial Attorney Member of New Jersey & Florida Bars December 3, 2009 Barbara K. Esquire State Attorney's Office 401 North Dixie Highway West Palm Beach, Florida 33401 RE: State of Florida v. Jeffrey Epstein Case No. 2008CF009381A Dear Barbara, Pursuant to our telephone conversation of November 30, 2009 and your subsequent email to me, I am providing the following information to you concerning Jeffrey Epstein's air travel from May 1, 2009 through November 30, 2009. As you know, Mr. Epstein was in the custody of the Palm Beach County Sheriff's Office until July 22, 2009. I have confirmed that since Mr. Epstein's release from custody, he has traveled twice by air. The first trip was on September 14, 2009 when he traveled by helicopter to Miami to meet with counsel. He returned that day from Miami to Palm Beach County by automobile. Larry Visoski was the pilot and from Miami to Palm Beach was the only other passenger. Both the trip and the mode of transportation were pre-approved by probation. On August 27, 2009 Mr. Epstein flew on a single engine Cessna aircraft to Sikorsky Helicopters in northern Palm Beach County. Larry Visoski and accompanied Mr. Epstein on this short flight. Once again the trip and the method of transportation were pre-approved by probation. There have been no other aircraft flights taken by Mr. Epstein during the time period. I am told there are not flight logs kept for the helicopter but I am enclosing the fuel receipt for the Miami helicopter trip as well as another document confirming the September 14, 2009 Palm Beach - Miami helicopter flight. I am also enclosing documents for the August 27, 2009 Cessna flight to Sikorsky Helicopters. On another note, there appears to be false information being presented to either the State Attorney's Office or the Probation Office about Mr. Epstein allegedly violating the terms of his probation. None of this is true and in fact Mr. Epstein has an unblemished record with probation without any violations since his being placed on supervision. I note that many of the false allegations against Mr. Epstein have been brought by the Scott Rothstein law One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 firm which has since filed bankruptcy as a result of massive fraud by one of its partners. It is alleged that they used their civil cases filed against Mr. Epstein as one of their more lucrative devices to perpetrate this fraud. Based on what I have learned and read, there have been false filings, forged judge's signatures, and forged Eleventh Circuit Opinions. It is also possible that other third parties have engaged in this conduct by falsely alleging Mr. Epstein has violated the terms of his probation. With this in mind, It appears that Mr. Epstein could be a victim of fabricated attacks designed to do nothing more than question his compliance with his probation and community control requirements. I truly want my client, as I am sure you do, to complete his probation without continued false accusations being made against him. I would suggest a meeting so we may discuss these problems. Given the fact that false accusations are being made against my client, I would take the unusual step of producing my client for such a meeting if you think it would be helpful. Please give me a call with your thoughts on this and whether those documents satisfy your request. Very truly yours) N. Goldberger JÅG/slm | 2633 Lantana
Lantana Fl 33
561-963-8821
www.pbflight
Bill To
Larry Visoski | | | | | | Date
8/27/2009 | Invoice #
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ENG. 2 EVENTS | LANDINGS | POWER | ENG. 1 ENG. 2 | | VISOSKI MIA 8/15/09 | VPL 1 | 12 | 2 | 2 | TORQUE | | | VISOSKI FXE 9/10 | | 1 2 | 2 | 2 | TOT/ITT | | | VISOSKI PBI-MIA 9/18/0 | VFR 1. | 23 | 3 | 3 | NI | | | VISOSKI FXE ALIGO | VER | .3 1 | . 1 | 1 | NZ | | | | | | | | QAT | | | TOTAL FOR THE DAY: | 3 | .7 8 | 8 | 8 | PA. | | | AIRCRAFT & ENGINE
FLIGHT HRS / CYCLES / RIN HOUR | | ENG. 2 ENG. 1 E | CLES TORQUE
ENG. 2 EVENTS | LANDINGS | I CERTIFY TRU
INSPECTION I | VAS COMPLETED | | TOTALS BROUGHT FORWARD: 749 | 6 749.6 | 1545 | (2) 2204 | 2194 | MAINTENANG | | | TOTALS FOR TODAY: 3 | 7 37 | - 8 | 8 | 8 | 01/1/100 | Visaski | | ACCUMULATIVE TOTAL: 753 | 3 533 | 1553 | @ 2212 | 202 | det | 26145582 | | | | | | 1.34 | NAME & CERT | 1FICATE NO. | | TYPE INSPECTION
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DUE DATE: | | | | | | | # PILOTS AND MAINTENANCE RECORD # PILOTS ENTER DISCREPANCIES - MECHANICS ENTER ALL MAINTENANCE PERFORMED | | REMARKS | |------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | 1 | LOGBOOK ENTRY: N491GM BELL 407 HOBBS 749.6
TESTED AMERIKING AK 350 S/N 35290240 ALTITUDE REPORTING MODE C AND FOUND 200 FEET | | ACTION | LOW RE-ADUSTED AND PERFORMED CORRELATION TEST FOUND SATISFACTORY
INSPECTED I/A/W FAR43 APPENDIX F (FAR91.413) AND IS APPROVED FOR RETURN TO
SERVICE. PERTINENT DETAILS OF THIS TEST IS ON FILE | | 2 | AT THIS REPAIR STATION UNDER W.O. 9204 DATE JUNE 9, 2009 | | CORRECTIVE | TROPIC RADID INC. 2695 N.V. 554 ST. HANGER 53-A | | 3 | STLAUDERDALE FL. 33309 FAA APPROVED REPAIR STATION & RIARSTOPI
FTLAUDERDALE EXECUTIVE AFPOST*ARCHER RASP* | | CORRECTIVE | TELEPHONE# 254-775-4838 | | 4 | | | ACTION | | | 5 | | | | Public Records Request No. 19-372 | | £00 ° | DEC-01-5000 LDE 02:24 FM | SIGNATURE FLIGHT SUPPORT IMAIM Invoice: 2022 Aircraft: N491GM Opened: 09/14/09 08:19:36 Closed: 09/14/09 08:28:46 Customer: N/A Employee: CLARA M 65.000 1 HANDLING CHARG 3101 Ref: MED HELI 1 LANDING FEE 3000 17.700 1 RAMP PARKING 3204 44.000 126.700 Subtotal: 7.0 SALES TAX 3.080 129.78 Total: Auth: 145803 129.78 AMERICAN EXP \*\*\*\*\*\*\*\*\*\*5014 Customer Signature I agree to the credit card amount shown and to perform the obligations set forth in the terms of the cardholder's agreement with the issuer. Your feedback is appreciated. Tell us how we did today by logging pr to www.signatureflight.com/survey and entering Access Code: 20092022149. Thank you for using Signature Flight Support. We put our name on the line. Worldwide. Every day. felicopter Juez Decrep P. 004 Public Records Request No. 19-372 DEC-01-5008 INE 02:57 PM Barbara Esquire State Attorney's Office 401 North Dixie Highway West Palm Beach, Florida 33401 33401\$4296 CO2i a nama resumme a net anales e de la 14. SUU | Case: 0008/1009381AMB | SAS 9003536 | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------| | < REQUEST | FOR ASSIGNMENT OF INVESTIGATOR | | To: INVESTIGATIONS | Date: November 30, 2009 | | From: BARBARA J. BURNS | Phone: (561)055-7100 | | State VS. JEFFREY M EPSTEIN | Div: M Judge: Jeffrey Colbath | | Case: 2008CF009381AMB | Charge: PROCURE PERSON UNDER AGE 18 FOR
PROSTITUTION | | Request For: Subpoena Duces Tecum Service | ) Sitness Locate | | Other: | Date Required: Dec. 7, 2009 | | Bailaidean Buins
To: Investigator
From: Supervisor
You have been assigned the above matter. Upo
and return this form to your supervisor
assignment, reviewed date. | | | | Investigative Supervisor | | Date Completed: 11/30/09 If
#Subpoena(s)served: #N
#Posted:
IF UNELE TO SERVE OR LOCATE
Other, completed as required
Investigator United Mileage: 12 | no assignment memo required, 2 hours
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COMPLETE - NON SERVICE FORM
Date: 15/20/09
Nemo attached: 16 | | | | ٠ #### OF THE FIFTEENTH JUDICIAL N AND DIVISION) NO. vs. E F . N Visoski DUCES TECUM: flight Logs May 1, YOU ARE HEREBY COMMANDED and and for :in 1 , Highway, 1 before the STATE ATTORNEY Assistant, Jaamsr,Y E EPSTEIN is the Defendant. You are flights : to ' 1.4 JEFFREY E. commanded to bring with you the complete concerning any and to with subpoena BARBARA J. witness in , t, SRPR' 0 -1 the within . IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA (CRIMINAL DIVISION) STATE OF FLORIDA CASE NO. 2008CF009381AMB DIVISION: W VS. JEFFREY E EPSTEIN TO: Larry Visoski DUCES TECUM: Flight Logs from May 1, 2009 through November 30, 2009 YOU ARE HEREBY COMMANDED to be and appear before the STATE ATTORNEY or his Assistant, in and for Palm Beach County, Florida, at the Office of the State Attorney, 401 No. Dixie Highway, West Palm Beach, Florida 33401, on Monday, December 14, 2009 at 10:00 am, for the purpose of a deposition decus tecum wherein the State of Florida is the Plaintiff and JEFFREY E EPSTEIN is the Defendant. You are commanded to bring with you the complete and official flight logs from May 1, 2009 through December 13, 2009 concerning any and all flights involving JEFFREY E. EPSTEIN. Failure to comply with this subpoena will subject you to contempt of Court. ling BARBARA J. Assistant State Attorney Fla. Bar No. 0865354 November 30, 2009 Received this subpoent on the 0 day of 0, 2009, and executed the same on the day of 2009, by delivering a True Copy thereof to the within named witness in the County of Palm Beach, State of Florida. SHERIFF, PALM BEACH COU TY By Deputy Sheriff | | SUU | |--------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------| | Case: 2008CF009381AMB | Investigative Cage No.: | | << REQUEST 1 | FOR ASSIGNMENT OF INVESTIGATOR >> | | To: INVESTIGATIONS | Date: November 30, 2009 | | From: BARBARA J. | Phone: (561) 355-7100 | | State vs. JEFFREY E EPSTEIN | Div: W Judge: Jeffrey Colbath | | Case: 2008CF009381AMB | Charge: PROCURE PERSON UNDER AGE 18 FOR
PROSTITUTION | | Request For: Subpoena Duces Tecum Service | Witness Locate | | Other: | Date Required: Dec. 7, 2009 | | Name: Larry Visoski (Helicopter pilot to Jeffr | ey Epstein) | | Fartare uninune | | | To: Investigator Chenn | Case: 5459003537 | | From: Supervisor | Date: | | You have been assigned the above matter. Upon
and return this form to your supervisor w
assignment, reviewed date. | completion of this assignment, sign, date,
with your memo, if required. Completed | | | Investigative Supervisor | | Date Completed: 12 1.64 If | no assignment memo required, # hours > | | #Subpoena (s) served: #No | t served: | | << IF UNABLE TO SERVE OR LOCATE C | OMPLETE - NON SERVICE FORM >> | | Other, completed as required | | | Investigator: Cille | Date: 17 1- 07 | | Hileage: | Date: 17 1-07
Memo attached: | | 1131 Pine Point Road - (1 | unig) | | West Palm Beach FL 33404 225
Tizlow - 11/09] | Public Records Request No. 19-372 | Sec. IF Case No: SA09003537, Defendant: EPSTEIN, JEFFREY E | Case
No
SA09O03537 | Date
12/01/2009
01:36
PM | Note
LOCATED
CURRENT
ADDRESS
FOR
PAUL
VISOSKI,
JR.;W/M,
2-25-1960:
1131
PINE
POINT
ROAD
WEST
PALM
BEACH,
FL
334O4-2251 | Relationship
LITTLES,
ERIC | Note
Type | |--------------------------|-----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------|--------------| |--------------------------|-----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------|--------------| 1 case\_note\_list | to | | |----|--| 15615151401 CONSUMER JUSTICE ATTORNEYS appeals #### Friday, November 20, 2009 Maureen Office of the State Attorney 401 N. Dixie Highway West Palm Beach, FL 33401 ## Re: B.B. v. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear As we discussed, I have agreed to cancel the deposition of ASA Daliah Weiss at this time. Based on the conversations with Ms. Weiss and you, I do not foresee the need at this time to reset this deposition, but I cannot completely foreclose the possibility of deposition in the future pending further discovery in the Epstein cases. As I mentioned to you, if I believe there is additional information that develops in these cases that would require me to reset Mrs. Weiss for deposition, I will provide you with notice prior resetting this deposition so that you will have an opportunity to address the court in a timely manner. Should you have any additional questions please do not hesitate to contact me at your convenience. Sinder RT. KUVIN 2025 PGA Boulevard Sulle 200 Palm Beech Gardens Floride 33410 561.515.1400 fax 561.515.1401 leopoick.win.com Public Records Request No. 19-372 CRASHWORTHINESS - MANAGED CARE ABUSE - CONSUMER CLASS ACTIONS - PERSONAL INJURY - WRONGFUL DEATH Do you want any response to the isourd? Phanko! NO Barb I am at a lost for words, and trying to hold the tears back, after ding about the sickening details of billionaire Jeffrey Epstein's case. I have to say in this instance, your office along with the entire judicial system, failed the people miserably, by not adequately punishing a chronic child molester and rapist. This man of wealth and prestige preyed on innocent, poor, GIRLS and systematically raped them at his will. He lived his life and continues to live his life, above the law, and once again has proven the corrupt nature of our system. If this happened to Tyrone from Dade County, he would be facing the death penalty. How can a person who molested one, let alone hundreds of girls, receive this joke of a jail sentence, and now be a free man?! How?!! Because he is rich? Just the thought of him being in his million dollar mansion, sexually raping these girls makes me sick. Now, I understand the pressure of taking on a powerful person with unlimited legal defense funds. Sometimes the premise, that any conviction is better than none can be appropriate, this was not that time. You did NOT need his cooperation nor did you need to strike a deal. Even without his testimony, and just the victims, your office could have put this monster away for at least 20 years, if not life. I'm sure you have read Conchitta 's piece on the Daily Beast detailing this monsters actions. If your office has not read the piece, you should by all means use it as a cautionary tale on how not to prosecute a rich child abuser and human trafficker. Now, I do not know the side story- your investigation, legal technicalities, how much hush money was paid out, ect ect. But I do know that after people such as Jeffery Epstein have raped the entire country of their retirement savings, he shouldn't be allowed to do the same thing to young children. I do sincerely hope, you, and your office did ALL you legally could have to put this man in prison. However after researching the case, it seems you failed to come down with any authority or justice. I only hope, the Palm Beach DA's office and the US DA can find further evidence, to re try him and put him away for good! It would do our society much good, and set a standard that no one person is above the justice system, especially child molesters. I would hope that as a lawyer, that is suppose to defend the public, you have a change of heart, and imagine if that was your little sister or daughter, and do ALL you can to bring this to a full trial with no deals. The American people deserve better, and so do the children that were abused. I hope you understand the anger and frustration being expressed and absorb it to the fullest. Because you and the whole DA's office need to know this- that monster doesn't deserve freedom! -A Concerned Patriot Dear p.s. I eagerly await ANY type of response at- JUNA UTUES $N_{2}^{-1}$ ٠ n 1.11 GAKLAND CA 946 31 JUL 2010 PM G T 5400 D.A. Lanna Belohlavek 500 Australian Ave., Fourth Floor West Palm Beach, FL 33401 33401-6223 հահունձեսիներումինումիներիներիներին - ÷ .................................... 2010 AUG 4 AT 11 14 . U.S. Department of Justice United States Attorney Southern District of Florida 500 Australian Ave., Suite 400 West Palm Beach, FL 33401 Official Business Penalty for Private Use \$300 > State Attorney's Office 401 N. Dixie Highway West Palm Beach, FL 33401-4209 > > ZI TT LIU L COUL GIAN Con ways STATES POSTA U.S. OF 0006899490 AUG 04 2 MAILED FROM ZIP CODE 33 02 1P 80 \$ 000.8 #### OFFICE OF THE STATE ATTORNEY INTER-OFFICE MEMORANDUM #### TO: Chief Michael Waites FROM: Investigator Glenn Wescott RE: State Attorney's Investigation 09-002456 #### DATE: August 24, 2009 #### \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* \* On 08/21/09 I was assigned to obtain copies of the security cameras and log in sheets for 1 Clearlake Plaza in West Palm Beach, FL which is the business address for Jeffrey Epstein. On 08/21/09 I received the copies of the log in sheet and noted that Mr. Epstein's name does not appear on the log in sheet which he would only be required to do if he were in the building after 1900 per the Property Manager, Mrs. On 08/24/09 I received the security camera videos which were formatted to DVD. I could not discern Mr. Epstein on the CD's but the camera angle is poor and does not allow one to see the entire area, just the door area. The DVD's and Log In Sheets were TOT ASA per her request. Investigator Glenn A. Wescott Office of the State Attorney 15th Judicial Circuit 401 North Dixie Highway West Palm Beach, Florida 33401 Visitors' Register | DAT | E NAME | FIRM | ADDRESS | TO SEE | |------|---------------|------------------|----------------------|-------------------| | 8/19 | Pita Pelacios | Composs Pent | STREET | | | 8/19 | Cuttly Aby E | Panller | CITY STATE | TIME IN TIME OUT | | 8/19 | Conde alles | ageoter | CITY STATE
STREET | | | | Ivener | UC | CITY STATE | | | 8/19 | freen | KGR | STREET
CITY STATE | 905 | | 8/19 | Andar | Fuchs | CITY STATE
STREET | TIME IN TIME OUT | | | Leslic | 1VC/13 | CITY STATE | TIME IN TIME OUT | | 8/19 | Mikenna | Vaychex | STREET | 9:12 | | 8/19 | CKCS | PAYCHEX | CITY STATE | | | | | 1. II CHEX | CITY STATE 1 | | | 8/19 | Dema Dair | Paycher | STREET | | | 8/19 | | | CITY STATE T | 9:46 TIME OUT | | 0/19 | Den Veil Will | Green worder | STREET | MEIN 9.50 11.17 C | | 8/19 | K. Newlod | Anderson Tolecom | STREET | | | elic | - 5 | | CITY STATE TH | 4:54 10:03 C | | 8/19 | 13013 | 601 | STREET | 10 41 391 | | 8/19 | Siliane | -17.00 | CITY STATE TIN | 10:45 - | | chia | | Mitur | | | | 8/19 | K. Kulane | Das | TREET | 0:44 | | 8/19 | 1 | Δ | | | | | M. Mann | Kess | | 0,5211.5 | | 8/19 | K. da losta | 61C | REET | | | / | | Compass a | | 19-372 .15 (CC | Visitors' Register | DAT | TE NAME | FIRM | | ADDRESS | TO SEE | | |--------|---------------|----------------------|-----------------|----------------|--------------------------------|------| | 8/19 | Willowslot | - Coly Ra | | | | | | 8/19 | M Boxanentur | " met Life | STREET | STATE | TIME O | UT | | 8/19 | Ed Turner | | CITY | STATE | TIME IN ST TIME OF | UT | | \$/19 | | MSC
Dempsy Paladh | CITY
6 STORE | STATE | IL:25 H:
TIME IN TIME OU | o+ | | | | verpsy that | CITY | STATE | 11:35. 12:0
TIME IN TIME OU | - | | 8/19 | 1-000 | Katzman
K 127 | STREET | STATE | | | | 8/19 | Tankel | Km | STREET | | 11:55 | 38 | | 8/19 | Sheila BROWN | metlife | STREET | STAIE | TIME IN TIME OUT | | | 8/19 | | | CITY | STAIE | 12/6 TIME OUT | | | 8/19 | Garyllbucht | Aicoh | СЛУ | STATE | 12:30
TIME IN TIME OUT | | | | Elane Manani | Swhich | STREET | STATE | 12:31
TIME IN TIME OUT | | | 8/19 | Subert Roman | Selucit. | STREET | SIATE | 12:4 7pm | | | 8/19 | Kevin Nekonna | CEMEX | STREET | SIAIE | TIME IN TIME OUT | | | 8/19 | | Division | STREET | STATE | TIME IN TIME OUT | | | 8/19 1 | Fidel njaraz | | CITY | STATE | 1234 100
TIME IN TIME OUT | | | 8/19 | | 1203 | СПУ | STATE | 102pm 1:59 | Ph - | | | Adam Morril | ErY | STREET | STATE | TIME IN 1:52 TIME OUT | k | | 8/19 | Kim Train | E-PY | STREET | | 157
S Request No. 19-97800 | | | | | | 1.0011 | SPublic Record | s Request No. 19-072 our | | AT-A-GLANCE M Visitors' Register | DAT | E NAME | FIRM | ADDRESS | TO SEE | |---------|-------------------|-----------------------|---------------------------|-----------------------------| | 11/09 | Michael ColANDRE | ADDREC TIM | STREET
CITY STATE | PROD-MAR. | | 3/19/0 | Alexander Carlesa | methe | STREET
CITY STATE | | | 19109 | Evan Balling-r | Atterbury | STREET
CITY STATE | 2219 3,58 C | | 5/19 | T. Benoit | Fridland | STREET
CITY STATE | | | 5/19 | Derek Jardeleze | Comex | SIREET
CITY STATE | тиме IN 2'. 40 2.'.45 | | 8/19 | Fandy Cera | y Samiek | STREET
CITY STATE | TIME IN 2: 43 11ME OUT | | 3/19 | Joder Suntamus | | ,
STREET
CITY STATE | | | 5/19 | Tyreli Morris | Flinn Berger | STREET
CITY STATE | TIME IN 3', 23 TIME OUT | | 6/19 | | Salnick | STREET
CITY STATE | тиме и Э и Э ч Э ч тиме очт | | 3/15 | | KGR | STREET
CITY STATE | | | da | George, Sell | former d | STREET
CITY STATE | | | 2/19 | DADould | BiRishart | STREET
CITY STATE | | | 3/19 | Kenda Clark | Lawoppie
Rm#1203 | STREET | 353 | | 3-19-09 | Ren Orten | #900
ERNST Typeing | STREET | 5:00 6:30 | | ₹∕ıq±⊃ | Beacher | Eisenberg | STREET | | | | | | CITY Putatic Records R | PRIMERT No. 19-37 ME OUT | Visitors' Register | DATE | NAME | FIRM | | ADDRESS | TO SEE | |-----------|------------------|--------------|--------|---------|-------------------------------| | 08/
20 | Many of FARA | CAMAX | STREET | | 644 | | | | 0/ | СПУ | STATE | GETO
TIME IN TIME OUT | | 18/10 | DA | 0m | SHREET | STATE | | | 120 | Howard Swerdloff | Metro Health | SIREET | | | | | (a) | 0 | CITY | STATE | | | 08/20 | P. Diane Lope | Paycher | STREET | STATE | TIME IN TIME BUT | | 08/ | | | STREET | | Charles Interesting | | 120 | hod the | Angelier | СПУ | STATE | TIME IN TIME OUT | | 120 | Tomyk | Payek | STREET | | TIME IN TIME OUT | | 081 | | 1010 | | STATE | TIME IN TIME OUT | | 120 | Lita PALAcios | Compass YAA | STREET | STATE | S: 45 TIME OUT | | 24 | | () | STREET | | | | 720 1 | NACT + Olsi- | sulf | CITY | STATE | TIME IN TIME OUT | | 120 . | TedKrigt | Paychex | STREET | | | | Del I | 1 | Muthal | CITY | STATE | TIMER 5 TIME OUT | | 120 | Viania Pitman | SVCS (LPL) | STREET | | MALINI INTERNA | | B/ | in | 10 | STREET | STAIE | | | 20 . | Kenn | R | CITY | STATE | TIME IN TIME OUT | | 08/ | | NORE | STREET | | | | ~~ ( | hi | Brigham | СІТҮ | STATE | TIME IN 3 6 TIME OUT | | 20 | Alvaro Perez | 1401 | STREET | | | | NP/ | river ever | | CITY | STATE | 1.32 TIME IN 42 TIME OUT 1.32 | | 20 8 | htbleel. | | STREET | STATE | TING IN SON TIME OUT 56 | | 25/ | | Δ | STREET | əiAlt | | | 120 f | RANK FERLAR | AUCHER | CITY | STATE | | Visitors' Register | DA | TE NAME | FIRM | | ADDRESS | TO SEE | |-----------|--------------------------|------------------|--------|-----------|------------------------| | 08/20 | Sule & Mui | Paychex | STREET | 958 STATE | | | 08/20 | Shelma Ballei | ( n ) l'in | SIREET | SIAIE | | | 8/20 | Am DeMath
An Bertikci | | CITY | STATE | | | | Ann Bertikci | Ken | CITY | STATE | 18:06 12:57 | | 8/20 | ABBASA | PAYCHEX | STREET | | 10 321 TIME OUT | | 10 | Jin Sunhop | PAYChex | STREET | STATE | TIME IN TIME OUT | | | | | СЛҮ | STATE | TIME IN 2.5 TIME OUT | | 20 | MAURICE FREDEROCK | Entre bay | STREET | STATE | 10.3 10.56 | | 25/20 | Michael Kapper | 1402 | STREET | , | | | \$/ _ | Iris Kapper
m // | 1 | CITY | STATE | TIME IN TIME OUT | | 70 /
B | 1 chapear | 601 | CITY | STATE | THENSE TIME OUT | | 20 | WSter | 60 | STREET | | Paketro C | | 20 | Lisathursa | Eiseobre | CITY | STATE | TIME IN OF TIME OUT | | 8/ | LISathumas | EISenar
Fauts | СІТҮ | STATE | | | 20 | N Aug | KARNE | STREET | STATE | | | 20 | | 1 | STREET | SIAIE | | | 1/2 | 1 Junio | They | CITY | STATE | ITIME IN HIME OUT | | 20 | Sean Kemp | faycher | CITY | STATE | 1139 11:40 C | | 20 | Mormey Calinte | Grear | STREET | | | | 20 | 0 | | CITY | STATE | TIME IN 11:40 TIME OUT | | | lan cy t | Purn | CITY | | Is Reguest No. 19-372 | | | 0 | | | 5 | | # TOWN OF PALM BEACH MEMORANDUM | TO: | The File | |-------|-----------------| | VIA: | Direct | | FROM: | Capt.
Frick | | RE: | Jeffrey Epstein | | DATE: | 08/20/09 | On 8/19/09, at approximately 1635 hours, I was advised that Jeffrey Epstein was walking northbound on South Ocean Blvd in the area of Brazilian Avenue. Based on my prior conversations with Probation Supervisor Gladstone, I made contact with him to discuss the possibility that this was a violation of Epstein's order of community control. I made contact with Gladstone who advised in his opinion that this was a violation and that based on FSS 948.06, we should arrested Epstein. I advised Gladstone that I needed a copy of his Order of Community Control in hand prior to making this arrest. At 1642, this order was e-mailed to my office computer. I reviewed and printed the order and responded to the area. At approximately 1653, I observed Epstein walking southbound on South Ocean Blvd near the intersection of Barton Avenue. At 1655 I requested a marked unit respond to Clarke Avenue and South Ocean Blvd as making contact with Epstein. Epstein was wearing dark sweat pants and a t-shirt. He was sweating profusely. As he approached, I identified myself and began my onscene investigation. This was documented in the CAD system, CAD #092310146, attached. At that time, Epstein advised that his probation officer, Carmen Sloan, had advised him he was allowed to walk to and from work, and that he was now en-route to work. He further advised that his work address was on Australian Avenue in West Palm Beach. I questioned Epstein as to why he was not on a direct route to his work, and why he was now walking south when he had just been walking north. He stated that he had walked to the area of the North Bridge, but considered it too busy, therefore he was returning to the Middle Bridge to cross into West Palm Beach. | ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ | ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ | ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ | |------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|-----------------------------------------------------------------------| | 8/20/09
11:00:01 | HTE CAD
D CALL INFORMATION | PAGE 1
092310146 | | Call Number: 092310146 SI 0
Entry Day/Tm: 8/19/09 16:55: | all Type.: 124 INVE | STIGATIVE Police
STIGATIVE Police | | CmnN:
Location: 100 CLARKE
City: PALM BEACH
Intersectn.: OCEAN | Block#: 100 | : 001 Police Dept
AV Apt: INTERSECTN
Loc ID: I Mapr: 16N
NTY | | Caller Name: Last:
Address:
City/State: | First:
Phone#: | Mid: See Caller:
Apt:
Source: SI | | Call Taker.: 9003 MARK
Dispatcher.: 9003 MARK | TYLER | PDC02A | | NA | RRATIVE | | | | | d the ocean 16:55:19 | | D10 Unit Stat | us History Informat | ion | | 8/19/09 16:55:02 4 Dispatch
8/19/09 16:55:02 6 At Scene
8/19/09 16:55:02 11 Assigned
8/19/09 17:14:18 16 Reset Un
8/19/09 17:26:47 20 Availabl | as Primary PR
it Time Chec RS | 7636 FRICK, RON | | D3 Unit Stat | us History Informat | ion | | 8/19/09 16:55:03 4 Dispatch
8/19/09 16:55:04 6 At Scene
8/19/09 17:14:09 20 Availabl | AT | 8806 GUELLI, JOS | | 109 Unit Stat | us History Informat | ion | | 8/19/09 16:55:06 4 Dispatch
8/19/09 16:55:10 6 At Scene
8/19/09 17:14:18 16 Reset Un
8/19/09 17:14:47 20 Availabl | AT
it Time Chec RS | 8141 KEEHAN,MIC | | חדפ | POSITIONS | | | 1 022 No Rpt/Asmt Comp | | 1 - 00-000000 Unit: D10 | All rights reserved. Use subject to License/Copyright Map Legend Directions and maps are informational only. We make no warranties on the accuracy of their content, road conditions or route usability or expeditiousness. You assume all risk of use. MapQuest and its suppliers shall not be liable to you for any loss or delay resulting from your use of MapQuest. Your use of MapQuest means you agree to our Terms of Use A: 358 El Brillo Way, Palm Beach, FL 33480-4730 | START | 1: Start out going EAST on EL BRILLO WAY toward TRAVERS WAY. | 0.1 mi | |----------------|----------------------------------------------------------------------|--------| | | 2: Turn LEFT onto S COUNTY RD/FL-A1A N. | 0.9 mi | | 1 | 3: Turn LEFT onto PALM WAY/FL-704 W.
Continue to follow FL-704 W. | 1.7 mi | | 21 82 | 4: Merge onto S AUSTRALIAN AVE/FL-704A N. | 0.6 mi | | END | 5: 250 S AUSTRALIAN AVE is on the RIGHT. | 0.0 mi | | B: 250 S Austr | alian Ave, West Palm Beach, FL 33401-5018 | | Total Travel Estimates: 8 minutes / 3.32 miles | | SVU | |----------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------| | Case: 2008CF009381AMB | Investigative Case No.: 0700
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0 Z | | | << REQUEST FOR ASSIGNMENT OF INVESTIGATOR >> | | To: INVESTIGATIONS | Date: August 21, 2009 | | —3,544E4
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From : -41190, | Phone: (561)355-7100 | | State vs. JEFFREY E EPSTEIN | Judge: SANDRA K. MCSORLEY
Div: W | | Case: 2008CF009381AMB | Charge: PROCURE PERSON UNDER AGE 18 FOR
PROSTITUTION | | Request For: PLEASE SERVE ATTACHED SUBPOENA
DUCES TECUM | (Witness Information/Locate) | | Other: | Date Required: 8/21/09 | | Name: 1 CLEARLME CENTRE LLC
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250 AUSTRALIAN BLVD
SUITE 105
, "5.3
WEST PALM BEACH,
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Date: | | e above matter.
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Mileage: | Memo attached: | Public Records Request No. 19-372 #### OFFICE OF THE STATE ATTORNEY INTER-OFFICE MEMORANDUM #### TO: Chief Michael Waites PROM: Investigator Glenn Wescott RE: State Attorney's Investigation 09-002456 #### DATE: August 24, 2009 \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*+\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* On 08/21/09 I was assigned to obtain copies of the security cameras and log in sheets for 1 Clearlake Plaza in West Palm Beach, FL which is the business address for Jeffrey Epstein. On 08/21/09 I received the copies of the log in sheet and noted that Mr. Epstein's name does not appear on the log in sheet which he would only be required to do if he were in the building after 1900per the Property Manager, Mrs. Horn. On 08/24/09 I received the secultilligra videos which were formatted to DVD. I could not discern Mr. Epstein on the CD's but the camera angle is poor and does not allow one to see the entire area, just the door area. The DVD's and Log In Sheets were TOT ASA per her request. Investigator Glenn A. Wescott Office of the State Attorney 15'1Judicial Circuit 401 North Dixie Highway West Palm Beach, Florida 33401 561-355-7118 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA (CRIMINAL DIVISION) STATE OF FLORIDA 1. 33 CASE NO. 2008CF009381AMB DIVISION: W vs. JEFFREY E EPSTEIN TO: 1 CLEARLAKE CENTRE LLC C/O WG COMPASS 250 AUSTRALIAN BLVD SUITE 105 WEST PALM BEACH, FL DUCES TECUM: COPY OF SIGN IN SHEET AS WELL AS THE DVR VIDEO FOR THE DATES OF 08/18/09 TO 08/20/09 YOU MAY COMPLY WITH THIS SUBPOENA BY MAILING THE INFORMATION TO THE STATE ATTORNEY'S OFFICE, C/O BARBARA 401 NORTH DIXIE HIGHWAY, WEST PALM BEACH, FL 33401. IF YOU HAVE ANY QUESTIONS, PLEASE CALL ASSISTANT STATE ATTORNEY LANNA BELOHLAVEK AT (561)355-7100. You are hereby commanded to comply with the request in the Subpoena in this case, on INSTANTOR, wherein the State of Florida is the Plaintiff and JEFFREY E EPSTEIN is the Defendant. Failure to comply will subject you to contempt of Court. August 21, 2009 Received this subjoena on the 2/ day of AuG, 2009, and executed the same on the day of Aug, 2009, by delivering a free Copy thereof to the within named witness in the County of Palm Beach, State of Florida. PALM BEACH COUNTY SHEALFE B Deputy Sheriff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA (CRIMINAL DIVISION) STATE OF FLORIDA 136- 00 CASE NO. 2008CF009381AMB DIVISION: W (KAMPOITON) VS. JEFFREY E EPSTEIN TO: 1 CLEARLAKE CENTRE LLC C/O WG COMPASS 250 AUSTRALIAN BLVD SUITE 105 WEST PALM BEACH, FL DUCES TECUM: COPY OF SIGN IN SHEET AS WELL AS THE DVR VIDEO FOR THE DATES OF 08/18/09 TO 08/20/09 YOU MAY COMPLY OFFICE, C/ HAVE ANY Q 7100. SUBBOENA BY MAILING THE INFORMATION TO THE STATE ATTORNEY'S 1 NORTH DIXIE HIGHWAY, WEST PALM BEACH, FL 33401. IF YOU L ASSISTANT STATE ATTORNEY LANNA BELOHLAVEK AT (561)355- You are hereby commanded to comply with the request in the Subpoena in this case, on INSTANTOR, wherein the State of Florida is the Plaintiff and JEFFREY E EPSTEIN is the Defendant. Failure to comply will subject you to contempt of Court. August 21, 2009 Received this subpoend on the 2/ day of 40, 2009, and executed the same on the day of 40, 2009, by delivering a frue Copy thereof to the within named witness in the County of Palm Beach, State of Florida. SHERIFE, PALM BEACH COUNTY Deputy Sheriff ## LAW OFFICES OF GERALD B. LEFCOURT, P.C. (212) 737-0400 # PRIVILEGED & CONFIDENTIAL ATTORNEY WORK PRODUCT # MEMORANDUM | DATE: | December | 20, | 2006 | |-------|----------|-----|------| |-------|----------|-----|------| FROM: Gerald B. Lefcourt Sheryl E. Reich Faith A. TO: Jeffrey Epstein FILE SUBJECT: Impeachment Material Set forth below is some of the information that demonstrates (a) that the Palm Beach Police Department ("PBPD") made a materially incomplete and materially inaccurate presentation of the facts in both the probable cause affidavit and in its release to the public of the Police Reports, and (b) why the State Attorney's decision to proceed as it did with respect to the bringing of any charges against Jeffrey Epstein ("Epstein") was not inappropriate.1 Note, though the Police Reports are on various dates, since they were released to the public with continuous pagination, we refer here simply to the "Police Report" and use the numbering provided in the version disclosed to the public. # I. Inaccuracies and Material Omissions from the Police Reports 1. Polygraph Examination and Report. On May 2, 2006, Epstein submitted to a polygraph examination in which he was asked (a) whether he had "sexual contact with (b) whether he "in anyway threaten[ed] (c) whether he was told by "that she was 18 years old"; and (d) whether he "believed was 18 years old". As set forth in the Report of the examination, the term "sexual contact" was given an extremely broad meaning in order to capture any inappropriate conduct that could have occurred.2 The results of the examination confirmed that (a) no such conduct occurred; (b) Epstein never threatened (c) told Epstein she was 18 years old; and (d) Epstein believed was 18 &lt;sup>1 This memo is not exhaustive of facts of which the defense is aware. Nor is it exhaustive of Epstein's defenses to the accusations. &lt;sup>2 The definition included: "sexual intercourse, oral sex acts (penis in mouth or mouth on vagina), finger penetration of the vagina, finger penetration of the anus, touching of the vagina for sexual gratification purposes, touching of the penis for sexual gratification purposes, masturbation by or to another, touching or rubbing of the breasts, or any other physical contact involving sexual thoughts and/or desires with another person". years old. Though the results of the examination were given to the PBPD and the PBPD was given an opportunity to meet with the polygraph examiner in order to satisfy itself as to the *bona fides* of the exam, representatives of the PBPD inexplicably declined to attend the meeting and no information concerning the fact of the exam or the results appeared in the Police Report; the probable cause affidavit; or the public release. 2. Meetings with the State Attorney's Office. On multiple occasions, defense counsel met with prosecutors and investigators in the State Attorney's Office. Though there is vague reference to one or more meetings with defense counsel (see, e.g., pages 64 and 87 of the Police Report), virtually no information provided or evidence from witnesses proffered is included in the Police Report or probable cause affidavit. Instead, there are misleading or false references to such meetings. So, for example, at page 64 of the Police Report, Det. Recarey claims he attempted to reach ASA Dahlia Weiss on December 20, 2005, but she was unavailable that day and for the entire week. In fact, on December 19, 2005, Det. Recarey met with ASA Weiss and Epstein defense attorney Alan Dershowitz - a meeting at which Dershowitz provided evidence impeaching (see below). This evidence included excerpts from MySpace.com webpage, which is not only unnoted in the Police Report, but credited as having been found by Det. Recarey. (Police Report at page 65.) In another example, the briefest reference is made to a conversation Det. Recarey had on June 1, 2006, with ASA Belohlavek regarding a meeting earlier that day between representatives of the State Attorney's Office and defense attorney Jack Goldberger (Police Report at page 87). Omitted are the facts of the meeting (Report at 87): In addition to the presence of other defense counsel, there was in attendance both the polygraph expert who administered the examination and a psychiatrist who had performed a rigorous psycho-sexual evaluation of Epstein and who concluded that Epstein was healthy. Both men were made available for questioning by the State Attorney and the PBPD; unfortunately, the PBPD failed to attend the meeting. Nor is there any mention of the presentation made by defense counsel in which the claims being made with respect to (by then, the sole focus of any potential prosecution) were rebutted. # 3. The Video Surveillance Equipment Located in Epstein's Office and **Garage.** Both the Police Report (page 43) and the probable cause affidavit (page 18) make particular mention of the PBPD having "discovered" video surveillance equipment, or "covert (hidden) cameras" (as the PBPD refers to them), at Epstein's Palm Beach residence, specifically in Epstein's garage and library/office. By its placement in the probable cause affidavit, it is clear that the reader is intended to assume a link between this equipment and "sex objects" and that the cameras were used for an improper purpose. As the probable cause affidavit states: Det. Recarey "located a colored armoire beside Epstein's bed that contained a bottle of 'joy jelly', which is used to provide a warm massage. Several massage tables were located throughout the second floor of the residence, including a massage table found in Epstein's bedroom. . " Indeed, much is made of the presence of this equipment, noting that it captured images of and others. (See probable cause affidavit at page 18). In particular, the probable cause affidavit notes that "on the first floor of the Epstein residence . . . [was] found two covert cameras hidden in clocks. One was located in the garage and the other located in the library area behind Epstein's computer. . . . the computer's hard drive was reviewed which showed several images of and other witnesses interviewed. All of these images appeared to come from the camera positioned behind Epstein's desk". (Id.) Omitted from the Police Report and the probable cause affidavit is the fact that the PBPD had known since 2003 about the presence of the cameras, and the specific reason for their installation. The cameras were installed in 2003 after Epstein discovered that large sums of cash were missing from his home. Indeed, not only were the cameras installed at the suggestion of the PBPD, but the PBPD initially provided equipment that did not work and thereafter assisted in the installation of the equipment Epstein purchased. The cameras ultimately served their purpose and captured the image of former employee Juan Alessi, removing cash from Epstein's briefcase after unlawfully entering the house. The recording of Alessi was turned over to the PBPD - indeed, to Det. Recarey himself. The characterization of the video equipment either as a surprise to the PBPD or as playing a part in the alleged sexual activity in Epstein's home (even though none of the complainants ever made any mention of such equipment, or ever placed any activity in the locations of the cameras), is false and misleading and suggests an intention to portray the facts to suit a particular goal. - 4. Broken "Sex Toys" in Epstein's Trash. The Police Report details police finding in Epstein's trash what is described as pieces of "sex toys" and that these "discoveries" purportedly corroborate witness statements. Omitted from both the Police Report and the probable cause affidavit is the fact that during the course of executing the search warrant on Epstein's home, the police realized that a key "sex toy" was in fact the broken handle of a salad server. Though the "sex toys" play a prominent role in the Police Report and probable cause affidavit, the Police Report was never amended to reflect the discovery of this new and highly relevant evidence. - 5. Failure to Consider Exculpatory or Impeaching Evidence. Other exculpatory and impeaching evidence known by the PBPD was omitted from the Police Report and probable cause affidavit by, in our view, manipulating the date the investigation was allegedly closed. According to the Police Report (at page 85), for the probable cause affidavit, and the PBPD had concluded its case in December of 2005". That assertion, which is false, conveniently resulted in the omission of all information adduced subsequent to that date. Thus, though the Police Report in fact contains information obtained after December 2005, the PBPD escaped having to consider, or even to include in the Police Report, the probable cause affidavit, or what it released to the public, all the exculpatory and impeaching evidence presented on behalf of Epstein, most of which was provided after December 2005. That evidence is listed below. # II. Unreported Criminal Histories and Mental Health Problems of the Witnesses Relied on in the Police Report and Probable Cause Affidavits. Virtually every witness relied on to support the Police Report and the probable cause affidavit has a background that casts significant doubt on whether the witness is sufficiently credible to support a finding of probable cause, let alone to sustain what would be the State's burden of proof at a trial. (Indeed, nearly all the witnesses, and certainly those deemed complainants, were friends, which undercuts any claim that one story corroborates another.) Though this evidence was submitted to the PBPD, none of it was included in the Police Report, the probable cause affidavit, or released to the public. Below we address solely the omitted criminal histories. Following that, we list other factors that make each witness unworthy of belief and incapable of withstanding cross-examination at trial – all of which was previously provided to the PBPD but omitted from the Police Report, the probable cause affidavit and the public disclosure. - 6. Juan Alessi: While the Police Report (at page 57) and the probable cause affidavit (at page 21) contain assertions by Alessi which allegedly support the bringing of criminal charges, omitted is the evidence revealing Alessi's evident mental instability; prior criminal conduct against Epstein; and bias towards Epstein. As the PBPD well knew, in 2003, Alessi was filmed taking money from Epstein's home. After being caught on videotape unlawfully entering Epstein's home and stealing cash from a briefcase, Alessi admitted to the PBPD that he entered the house unlawfully on numerous occasions, stealing cash and attempting to steal Epstein's licensed handgun (which in fact went missing). Officers assigned to the investigation prepared a report detailing Alessi's confession. Also known to the PBPD, but omitted from the Police Report, is that Alessi claimed he intended to steal the gun in order to kill himself. Though this information is clearly material to any determination of credibility, and was specifically known to Det. Recarey at the time the Police Report and probable cause affidavits were written, it was omitted. - While the Police Report and probable cause affidavit rely on statements of low the PBPD, that casts doubt on **Foreign Control** omitted is evidence, known to the PBPD, that casts doubt on **Foreign Control** or dibility and sustainability as a witness. Omitted from the Police Report and probable cause affidavit is **Foreign Control** federal fraud conviction, which defense investigators discovered and turned over to the PBPD during the course of the investigation. **Foreign Control** over to the PBPD during the course of the investigation. 7. 8. While the Police Report and probable cause affidavit rely on statements of the step-mother of the step-mother of the step-mother of the step-mother of the step-mother of the step-mother of the step-mother of the state of the state of the probable cause affidavit is state from the Police Report and the probable cause affidavit is state conviction for identity fraud – criminal use of identification information. This information, uncovered by defense investigators, was also turned over to the PBPD during the course of the investigation. - 9. was the source of the vast majority of the allegations made about Epstein. While the Police Report and probable cause affidavit rely on numerous assertions, all but omitted is any reference to the facts known about her by the PBPD, specifically, that at the time was making these assertions - 10. While the Police Report and probable cause affidavit contain numerous assertions of contacts with law enforcement. Among those are multiple runaway complaints by her parents and her assignment to a special high school for drug abusers. In addition to the prior criminal history of each of these critical witnesses, all of which was omitted from the Police Report and probable cause affidavit, significant additional material information concerning the credibility of these key witnesses was provided to the PBPD but never included in the Police Report, the probable cause affidavit or the public release. Ш. 11. "came forward" (as the probable cause affidavit characterizes it at pages 10-11), claiming she had knowledge of "sexual activity taking place" at Epstein's residence and misconduct by Epstein. Thus, it becomes clear that the assertions of misconduct by Epstein were likely motivated by a strong desire to avoid the repercussions of her the assessing her credibility as a witness. 12. Was 18 at the Time She Inaccurately Alleges to Have Engaged in Sexual Conduct with Epstein. Epstein denies he ever had sex with However, even if he did, irrefutable evidence, in the form of a credit card receipt, was presented to the PBPD and the State Attorney's Office which demonstrates that any such encounters occurred at a time when was already 18 years of age. (Indeed, it is our understanding that it was this information, combined with the character and credibility problems presented by the facts noted herein, that led the State Attorney's Office to conclude that was neither credible nor a proper complainant.) This information, though known to the PBPD, was omitted from the Police Report, the probable cause affidavit and the public release. 13. Steals From a An investigation by private investigators working for the defense revealed that in late 2005 | | was employed at a in Florida. On October 28, 2005. | |-----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | | was employed at a second was enclosed in Florida. On October 28, 2005,
some three days after was caught by a
manager as attempted to leave the store with merchandise in her purse,
the security tag still attached. (According to a report of the incident, was
found "kneeling on the floor digging through her purse". As the manager
approached, and "pulled out a pair of black SLT panties that had the sensor
on them".) Seeing the manager, claimed "someone is trying to set me
up". Following an internal investigation, which disclosed additional thefts
from both the store and a customer, she was fired. (In addition to the theft
above, she was seen by co-workers with store merchandise in her car; she was
believed to have engaged in a fraudulent "return scheme"; and she obtained a
pair of shoes from another store in the same mall by exchanging them for a
pair of just purchased men's shoes inadvertently left behind by a customer).
In a recorded interview by a Loss Prevention manager, "admitted to
merchandise theft of \$209 [and asserted] "that her reason for stealing was that
she understood she was not getting paid enough and was struggling
financially". This information and supporting documentation was duly | | | presented to the PBPD, but was never included in the Police Report or
probable cause affidavit, and never released to the public. | | 14. | Lies on MySpace About
Termination. Also uncovered by defense investigators was
dissembling version of the debace on her "MySpace"
webpage. There, the announced that she " forgot to let everyone know I
quit my job at the They said they suspected me of 'causing losses to their
company' – which by the way is bullshit. I was 'by the book' on
EVERYTHING!!! I got so fed up in that office that I handed the Loss
Prevention lady back my keys and walked out". That story is not reconcilable
with the taped confession. This information and supporting documentation
was provided by the defense to the PBPD, but was not included in the Police
Report or probable cause affidavit and never released to the public. | | 15. | Lies on her Job Application. Additional
information on MySpace webpage located by defense investigators
casts further doubt on her credibility and undermines her ability to be a
witness. For example, she boasts to having engaged in a fraudulent scheme to
get hired by MySpace webpage explaining, "My, it was so funny – I used [my
boyfriend] as one of my references for my
called me back and told me that my gave me such an outstanding
reference that she did not need to call anyone else back, he got me the job!
Just like thatI lied and said he was the old manager at the she
bought it" This information and supporting documentation was provided
by the defense to the PBPD, but was not included in the Police Report or
probable cause affidavit and never released to the public. | | 16. | Boasts About Her Marijuana Use. Also on her MySpace
webpage can be found admissions of purchasing and using marijuana
and marijuana paraphernalia. Specifically, and states she is "19 years old" | 16. 15. and "can't wait to buy some weed!!! ... I can't wait!!! ... (Hold on: let me say that again) I can't wait to buy some weed!!!... I also want to get a vaporizer so I can smoke in my room because apparently there are 'narcs' everywhere". also posted a photograph of a marijuana signature and labeled it "what heaven looks like to me". This information and supporting documentation was provided by the defense to the PBPD, was not included in the Police Report or probable cause affidavit and never released to the public (although there is both a fleeting reference in the Police Report to marijuana with her boyfriend (at page 67) and in the probable cause affidavit to marijuana (at pages 10-11)). 17. # Lies, Alleging Defense Investigators Impersonated Police Officers. During the course of the investigation by the PBPD and the State's Attorneys Office, the defense was notified that a witness claimed that defense investigators had impersonated police officers in an effort to get her statement. The defense subsequently concluded that these accusations were made by (A reference to this accusation was included in the Police Report (at page 67) and the probable cause affidavit). Defense counsel immediately questioned the investigators and learned the accusation was baseless. The investigators' notes, which describe the investigators' conversation with claims of police impersonation. These notes, which were freely reproduced for the PBPD, demonstrate that the investigators gave a business card clearly identifying them as private investigators. The notes provide contemporaneous evidence that initially declined to speak to the investigators because she said she "does not speak to cops", to which the investigators responded they were not "cops". Despite having this information from defense counsel, the PBPD failed to include it in the Police Report or probable cause affidavit, including only fantastic, and false, claims and that defense counsel was investigating the allegations. #### IV. 18. # Police Contacts – Drugs, Alcohol, Running Away From Home. has a history of running away/turning up missing from her parents' various homes; of using drugs and alcohol; and of associating with unsavory individuals. For example, a Report details how shortly after returning to Florida from to live with her father, on police were called to the home after her father reported that and her were missing. As it turned out, the had voluntarily absented themselves. They stayed out all night and were returned home, drunk and high, by a helpful "drug dealer". This event coincided by a few days with a having been found at an "inappropriate location" by police who this time were called by mother because of yet another unexplained absence. Although this information, material to determining credibility, was provided by the defense and known to the PBPD, it was never included in the Police Report or probable cause affidavit or released to the public. 19. MySpace Webpage States She is 18, Drinks, Smokes, Does Drugs, Gets into Trouble, Has Beaten Someone Up, Shoplifts, Has Skinny Dipped, Has lost her Virginity, Earns \$250,000 or More, and Contains Naked and Provocative Photographs. Defense investigators also found that maintains a webnage on MySpace.com. The first image seen on the webpage, the photo chose to represent her, is that of a naked girl (presumably provocatively lying on the beach. As late as July 2006, well after commencement of the PBPD investigation, was (evidently) falsely representing herself on the website as being 18 years old. This evidently false representation corroborates Epstein's assertions (confirmed by the polygraph examination), that specifically represented to Ep that she was 18 years old. The illuminating webpage also contains assertions that of all her body parts, she "love[s] her ass", she drinks to excess, smokes, uses drugs, "gets into trouble", has beaten someone up, has shoplifted "lots", "already lost" her virginity, earns "\$250,000 and higher", and has no regrets in life because "you only live once". As with the other impeaching information, this material, vital to determining credibility, was provided by the defense to the PBPD but was never included in the Police Report or probable cause affidavit and never released to the public with the other details of the case. #### V. Juan Alessi - 20. Juan Alessi Admitted Burglarizing Epstein's Home and Mental Health Issues. As touched on above, in 2003, Epstein noticed that significant amounts of cash were missing from his Palm Beach residence. In an effort to identify the thief, Epstein had video surveillance equipment installed in the library/office and garage. Caught on tape was former employee Juan Alessi breaking in and stealing cash. The video evidence was turned over to none other than PBPD Det. After being confronted, Alessi admitted to that break-in and claimed he was suicidal and wanted to steal a gun (which Epstein maintained a license and permit for) with which he could kill himself. He took cash instead. However, Alessi also admitted that he had repeatedly entered the home unlawfully in order to steal money. Although these facts were known to the PBPD, and in particular by Det. Alessi's criminal history and evident mental instability were not included in the Police Report or the probable cause affidavit or released to the public. - 21. Juan Alessi Lied. Alessi is significant, of course, because the Police Report includes a statement by Alessi that "the bed would almost always have to be made after the massage[s]" (at page 57). The implication being that Epstein (and presumably the masseuse) used the bed during the massages. Though the Police Report is devoid of any accusation by any woman that any activity ever occurred on the bed, no evidence concerning Alessi's motive to lie, his criminal history, his mental instability or the factual lapses appears in the Police Report, the probable cause affidavit or the public disclosure. # Claudette Hughes | Address and the second filling | | | |--------------------------------|-----------------------------------------|--| | From: | | | | Sent: | Thursday, September 20, 2007 6:17 PM | | | To: | Barry Krischer | | | Cc: | Lanna Belohlavek | | | Subject | t: RE: Meeting with Epstein's attorneys | | Hi Barry – I just left a voicemail for Claudette, but figured I would send this to you, too. Our plea negotiations are not going very well, and I have given the defense a deadline of tomorrow afternoon to provide me with a signed agreement. If we cannot reach such an agreement, then I need to indict the case on Tuesday and I will not budge from that date. During my last phone call with defense counsel, he told me that they have changed their minds again, and they only want to plead to state charges, not concurrent state and federal. I said that is fine, but we will need a signed non-prosecution agreement (between the defense and us) by tomorrow afternoon, and an agreement at least verbally worked out with your office by Monday. I just think that Mr. Epstein is having second thoughts about spending time in jail and paying damages to the girls. I know you are out tomorrow, but if something comes up, I will call Claudette and e-mail you. Thanks. Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Phone Fax 56 3 One Clearlake Centre. Suite 1400 250Australian Avenue South West Palm Beach. FL 33401 IMPORTANT MESSAGE FOR TIME 11:50 A.M. 9/20 DATE Jold berger M\_~ OF\_ 659-8300 PHONE. AREA COCE NUMBER EXTENSION 346-8973 TELEPHONED V PLEASE CALL CAME TO SHE YOU WILL CALL ABAIN WANT'S TO SEE YOU RUSH RETURNED YOUR CALL WILL FAX TO YOU hins Viers MESSAGE SIGNED D TOPS FORM 4000 TTERBURY GOLDBERGER & WEISS, P.A. # JACK A. GOLDBERGER #### JASON S. WEISS Board Certified Criminal Trial Attorney - Member of New Jersey & Florida Bars Barry number. Here is let me know what he has to say because Jay leftowtz has to follow up w/a call to him to findlike. Enclosing some fun reading on your Oefenhil Jack One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 Public Records Request No. 19-372 p 561.659.8300 f 561.835.8691 www.agwpa.com #### JEFFREY EPSTEIN Jeffrey Epstein is a person who, having been raised in modest, lower middle class circumstances in New York City, parlayed an aptitude for Mathematics, a teaching experience in a private school, and a chance referral to a Wall Street executive into a unique, niche business to the wealthy which in turn has made him a wealthy person. While this represents Jeffrey's outward achievement in life, it is hardly the measure of the man. To those who have known him long or intimately, he is a loyal and unselfish friend who has a playful sense of humor. To those in the scientific, education, wellness, and civic communities who have benefited from his largesse, he is an unparalleled patron seeking nothing for himself. Finally, and most importantly, to those who work for him at every level, and to many of those ordinary citizens he has learned of, he has been an extraordinarily generous and understanding person, mentor, and friend. #### Personal History Jeffrey Epstein was born in the Coney Island section of Brooklyn, New York in 1953. One of two sons born to Seymour and Paula nee Stolofsky Epstein, Jeffrey was raised in modest lower middle class circumstances in a longstanding Jewish neighborhood. Jeffrey's father supported the family as a laborer for the New York City Department. Jeffrey's mother was a housewife until Jeffrey and his brother were in high school when she went to work for an insurance agency. Jeffrey recalled that, during his youth, the family often played a card game called "Concentration" for entertainment from which he may have developed his early acumen for numbers. Jeffrey described a normal family upbringing in which he felt economically and emotionally secure. Jeffrey attended public schools where his aptitude in mathematics became evident early on. He skipped the third grade at P.S. 188 and was subsequently placed in a special program which resulted in his skipping the eighth grade at Mark Twain Junior High School. After his family moved to Seagate, Jeffrey was graduated from Lafayette High School in 1969 at the age of sixteen. Thereafter, continuing to live at home, Jeffrey attended Union in Manhattan for two years where he studied Math and Physics. Jeffrey dropped out of Union and took independent courses at New York University. During this period, Jeffrey drove taxicabs summers in New York City for spending money. 1 Around 1974, Jeffrey decided to try his hand at teaching and obtained a teaching position in mathematics with an annual salary of \$12,000 at the Dalton School, a highly respected private school in uptown Manhattan which caters to the wealthy. Children in his classes included, for example, those of Robert Redford, Joel Grey and those of wealthy financiers. This was a social class to which Jeffrey had not previously been exposed. As a teacher, Jeffrey was commended for being lively, interesting, and uniquely gifted in presenting the material in a way which challenged the students. As matters would turn out, Jeffrey's experience at the Dalton School would become lifealtering on a number of different levels. As Jeffrey recounts the key event, he was urged by a student to attend an art gallery opening which he reluctantly agreed to do. While there, Jeffrey was approached by a parent of one of his students who had been told that Jeffrey was an especially talented mathematics teacher. The parent asked him if he had ever considered working on Wall Street (Jefftey states that at the time he did not even know where Wall Street was), and referred Jeffrey to Alan Greenberg, then a high level executive at Bear Stearns. During his subsequent interview with Mr. Greenberg, Jeffrey admitted that he did not know what a change in the or a bond was. Mr. Greenberg explained that he had detected a sea and bonds market from qualitatively based valuation to quantitatively based valuation. Based on Jeffrey's mathematics aptitude, Mr. Greenberg offered him a job on the spot. Jeffrey agreed and started with the firm at the end of the school year. Jeffrey utilized his mathematics expertise in becoming an adept options trader, and came to know a number of successful investors. His success in the position is reflected in the fact that by 1980 he had become the youngest limited partner in the firm. Believing, however, that he could do better on his own on the outside, he decided to resign from Bear Steams in 1981. Capitalizing on his knowledge of and experience investing in esoteric financial instruments at Bear Steams, combined with his exposure to the unique family and financial problems of the "hyper-rich" gained from his experience at both Bear Stearns and the Dalton School, Jeffrey started a business called J. Epstein & Company (now Financial Trust Company) wherein he acts as a family advisor to the "hyper-rich." The services he provides consist of a broad array of financial advice (on investment, trusts, estates, asset allocation, etc.) and organization and management of the client's family office. The premise for the business is simple, if counter-intuitive: extreme wealth brings a host of unique and often intractable problems to its possessor, i.e., family, security, investment, tax planning, estate planning, etc. Jeffrey has studied families possessing such wealth, offers advice in all of these areas and, in the process, insulates the family head from the passions and emotions of other family members affected by the decisions of the family head.1 In essence, Jeffrey offers new potential clients the scenario of "no longer having to worry about their money." Jeffrey continues in this unique "niche" business to this day. The business is currently based in the U.S. Virgin Islands, with New York City being the base of his charitable operations. Jeffrey's business and personal interests currently employ approximately 160 people. Of these, however, he is the only income-producing person. Jeffrey is single, having never married or fathered any children. He has shied away from becoming a parent because the demands of his business would not allow him the kind of time and presence needed to be a good parent. During his adulthood, Jeffrey has had two long-term relationships: the first with Eva Andersson from 1981 to 1990, and the second with Ghislaine Maxwell from 1991 to 2000. (These will be treated in greater detail below.) Jeffrey currently maintains residences in New York City; West Palm Beach, Florida; the Virgin Islands; Santa Fe, New Mexico; and Paris, France; as he was enrolled as a visiting fellow at Harvard, he also has a rented apartment in Cambridge, Massachusetts. Jeffrey has always been shy socially but is articulate and engaging in person. He has preferred to maintain his privacy despite his business associations with many wealthy and well-known people in New York City and elsewhere. In 2005, Jeffrey agreed to accompany and fly former President Bill Clinton on his AIDS Initiative journey to Africa. While Jeffrey does not regret his decision to do so because of the great good that it did, it has also had the collateral effect of raising Jeffrey's profile in the media and otherwise impacting the quiet life he has sought to live. &lt;sup>1Jeffrey offered the following example. The daughter of a client becomes engaged. Because of the difficulty of knowing whether her suitor is motivated by love or by money, a pre-nuptial agreement is called for. Were the client to insist on this with his daughter, he might well incur her wrath because of the implicit questioning of the motivation of her betrothed. With Jeffrey as the family advisor to the client, however, it would be he who would deliver the news to the daughter, and it would be he who would incur and absorb her wrath, thus insulating the client from these unpleasantries. #### Personal Characteristics Friendships. Despite his worldly success, Jeffrey has maintained close relationships with several of his friends from his boyhood on Coney Island. Each of these friends attest to the loyalty, generosity, and accessibility Jeffrey has always accorded them. of New York City, for example, wrote as follows: It's difficult to express how much Jeffrey's friendship has meant to me over the course of my life, but he is nothing short of being my guardian angel. I have been blessed with a lifelong friend who regardless of the stresses of his own work and life, always makes time to listen and talk to me with gentleness, wisdom and humor. I've watched Jeffrey grow from boyhood into one of the hardest working, responsible, and generous men I know. For instance, when the time came to send my son to kindergarten, I wanted him to get the best possible education but our local public school was a failure and my husband and I couldn't afford to send him to an independent school. Jeffrey understood how much I valued education, and empathetically volunteered to cover the costs of our son's education. This past June, our son graduated from Columbia University with honors, and it would not have been possible without Jeffrey's long term commitment and generosity. Terry B. Kafka of Dallas, Texas, another friend who has known Jeffrey since 1958, wrote: > From the time we were junior high school students, when it seemed I was always in need of math and science tutoring until today, when I frequently call upon him for business advise, Jeffrey has always dropped what he was doing to listen and help.... > I am aware of Jeffrey's contributions to charitable causes and programs that he believes will make a difference to mankind and society – many of which are frankly over my head. On a personal level, I can attest that he is also caring when it comes to his friends. I recall a few years ago when he spent a good amount of on-on-one time with my 19 year old son Philip to help him sort out academic problems he was having. Eisenstein, O.D., also of Dallas, Texas, another long-time friend from Jeffrey's youth, recalled a number of jointly shared experiences from their younger days, including the fact that they both drove New York City taxicabs during college summer breaks. Eisenstein related a story from their youth which attests to the playful side of Jeffrey's nature: In high school, although we both were excellent academically, we were jokers in physical education. We were in great physical shape, but we just didn't take the class seriously. One month before graduation, our phys-ed teacher called us into his office and informed us that even though we were "two smart boys", we would not graduate because we would get a failing grade in phys-ed. We asked what we could do to turn it around, he said it was too late. After 10 minutes of negotiating with our teacher, Jeff convinced him that we would do anything he asked us to do until graduation. Well, Jeff managed to volunteer us to not only lead gym class every day, but we both had to double every exercise that the rest of the class did ... including track. Our gym teacher gave us "C" and we graduated. Eisenstein summarized the nature of his longstanding friendship with Jeffrey in the following words: Over the years, his genius has taken him to achieve levels of success unattainable by anyone I've ever met. No matter how busy he ever is, no matter where on earth he is, whenever I needed advise, or just talk to Jeff, he was always there. As we've gotten older, our lives have become more complicated, but we have never missed calling each other on our birthdays. It's a small, silly thing, but how many childhood friends do you know, who have never forgotten your birthday? The most important thing to me is that as vast a difference [as] our worlds are, our long-term, deep seated friendship is the strongest lifelong friendship one could ever have; it's just not like recently acquired friends, business associates, or even family. People who are fortunate to have these kind of friends are the only ones who could comprehend this special relationship. Jeffrey has had two long-term intimate relationships with women during his adulthood. In about 1981, Jeffrey met Eva Andersson (now Anderssontion), then 20, who was a Swedish model and former Ms. Sweden. They developed a long and still enduring friendship. The relationship endured for eleven years as an intimate one. During that time, Jeffrey encouraged Eva to fulfill her dream of becoming a doctor. He encouraged her and set about to pay her expenses at medical school in Sweden. She reported that he frequently flew over to see her and ensure that she was keeping up with her studies. When she continued her medical studies in California, Jeffrey was there to cheer her on and pay her expenses. She successfully completed medical school and presently works in New York City as a well-regarded internist. When it became clear, however, that the demands of Jeffrey's life could not include staying in one place and having a family, Eva and he realized that they had no future as a family unit. They parted amicably. Eva eventually married and has had three children. This notwithstanding, they have continued to speak with each other nearly every day (as does they have known each other. She described their current relationship as follows: > Today [Jeffrey] is a very close and important friend to my family. He is the and is close friend of my husband as well. Whenever Jeffrey is in New York, he will always come over in the evening and visit with us, help with their math homework, and conduct science O & A at the dinner table. He will always remember the way and he is constantly on the lookout for educational games for the four years ago when I had a cancer scare, Jeffrey was extremely supportive in visiting me everyday in the hospital. I could not ask for a better friend of Jeffrey has enjoyed an especially close relationship with **and the second of** wrote glowingly of their weekly science lesson when "Uncle Jeff," as she calls him, takes time from his personal and business schedule to go over to her apartment and discuss science and mathematics lessons she is learning at school. They might talk about such things, for example, as why the sky is blue or how fast light travels. After their lesson is over, they then spend some time at the piano where "Uncle Jeff" helps her work on her singing voice (even though, as she knows, "Uncle Jeff" does not have any real expertise in this area). The closeness of their relationship is perhaps best suggested, however, by an incident One of the nicest things anyone has ever done for me happened about 2 years ago when I was at ballroom dancing class. It was father-daughter dance day and unfortunately my father was stuck in a business meeting. I didn't know what I would do because you had to bring your father to the dance class. I got to the class alone, but then soon enough a quick phone call to Uncle Jeff didn't leave me standing there, alone for more than 10 minutes. Uncle Jeff substituted for my father that night, and the way he rushed to the class felt exactly like having my father there. After Eva and Jeffrey decided to put their relationship on a platonic basis, Jeffrey entered into another significant relationship with Ghislaine Maxwell, then 29, beginning in 1991. Ghislaine reported that she had come to New York City at a very dark time of her life. Her father, Robert Maxwell, a well-known publisher, had been found dead floating in the Atlantic Ocean, having gone overboard from a yacht. Her two brothers were involved in subsequent criminal proceedings related to the death, for which they were eventually acquitted. Ghislaine had no close friends in New York City at the time. Ghislaine met Jeffrey through mutual friends. She found the friendship immediately rewarding, as he engaged her in intellectually stimulating conversation. Moreover, Jeffrey understood that there were few bright spots for her during that period, and he never allowed her to become despondent. He understood that there were practical things he could do for her. He gave her books to read – good novels, scientific studies – containing issues to challenge her mind. Then they would discuss the issues and, in the process, take her outside of her personal concerns. Jeffrey had the insight to take her to comedy clubs on a weekly basis. This she found enormously palliative in relieving her depression. She believes that without Jeffrey at that time, she would have likely fallen into a deep depression. Jeffrey also offered to arrange for Ghislaine to secure a loan that would help her get a foothold in the business world. She explained that Jeffrey's way of helping friends with his money is always with a view toward maintaining their dignity. He would never just give out money as it is too demeaning to the recipient. When he gives money to people he does not know, it is always anonymously so that the recipient feels no need to give it back. These gifts are meant to allow the recipient to continue the work that Jeffrey finds interesting and useful. In the case of Ghislaine, Jeffrey arranged for the loan, which she subsequently paid back. In this way, she was able to maintain her self-respect. Over time, their relationship became intimate. However, as with Eva, it ended amicably around 2000 upon the realization that the nature of the demands of his work, i.e., the long hours and the frequent travel to maintain contacts around the world, precluded a good married life with children. Ghislaine and Jeffrey remain friends to this day. She wrote of their relationship: > My experience of Jeffrey, is of a thoughtful, kind, generous loving man, with a keen sense of humor and a ready smile – a man of principles and values and a man of his word. If he made a promise, he would always follow through. In fact, I never saw him break a promise. He is disciplined in business and conscientious. A man always quick to help someone who is down, or to offer an opportunity to someone to pursue a dream or a goal. Generosity to Educational, Wellness, Civic and Scientific Organizations. Jeffrey has been extraordinarily generous to a host of educational, wellness, civic, and scientific organizations. Between 2000 and 2006 he donated personally, through his business and interests, and through foundations he had established,2 a total exceeding \$16,000,000. The good generated by his largesse is suggested in the following examples. Jeffrey has been a benefactor to a number of educational institutions, but perhaps none more so than Harvard University. One example arose out of a need of the Jewish community at Harvard to have a new Hillel Center built to **sector** Jewish social and religious life at the university. The fundraising campaign was having difficulties when Henry Rosovsky, then **sector** of the Faculty of Arts and Sciences, decided to approach Jeffrey. Rosovsky wrote: > At this point I approached Jeffrey and suggested that a \$2 million gift would allow him to have his name on the building. It seemed to me a tempting proposition. To get your name on a Harvard building is a rarity and the cause was worthy. I do not remember all the subsequent details, but in essence this is what happened. > Jeffrey told me that he would raise the naming gift and that he certainly did not want his name on the building. Leslie Wexner would also participate and he did not want his name on the building. Indeed, he had decided – by himself or jointly with Wexner – that my name should be on the building because I had been associated with the institution for such a long time. I fully recognized the generosity and modesty of this suggestion and greeted it with mixed feelings. I did not feel deserving of this honor but without the Epstein-Wexner participation there would have been no new building and that would have been an enormous loss to the community. The building that now stands on the Harvard campus is the Riesman Center for Harvard-Radcliffe Hillel at Rosovsky &lt;sup>2 The Jeffrey Epstein Virgin Islands Foundation, Inc. and the C.O.U.Q. Foundation. gifts to be anonymous. Where this is not possible, he nonetheless does not seek the spotlight and makes it clear that nothing in return is expected. Jeffrey has also been an important benefactor to the Scholar Rescue Fund of the Institute of International Education. This fund is designed to provide support and safe haven to scholars who would otherwise be silenced, imprisoned, or even killed in such places as Iraq, Iran, Rwanda, and Sudan. Jeffrey has also been one of the major sponsors over the last several years of the "Female Economist of the Year" award offered by the Stockholm School of Economics. Jeffrey and one of the foundations he has created were the original sponsors and creators of "The Prize for Promise," a national award program designed to "identify post-graduate women of exceptional ability, ambition, brilliance, courage, dedication, and vision" to encourage them to pursue their chosen of endeavor to make improvements in the world. Yet another example of Jeffrey's generosity in the educational arena arose during his trip through Africa with former President Clinton. Jeffrey approached the President of Rwanda and offered to pay the room, board, and tuition for two worthy Rwandan students to earn an undergraduate degree in the United States. Jeffrey has made good on this promise through the Clinton Foundation, and the two students are currently enrolled at the City University of New York where they are expected to graduate in 2008. Jeffrey has also been a generous contributor to a number of wellness organizations. In particular, he has donated significant sums to the Ovarian Cancer Research Fund, the Alliance for Lupus Research, the Michael J. Fox Foundation, the Continuum Center for Health & Healing, the Institute for Music and Brain Science, and the Center for Health and Healing. Jeffrey has also been a long time benefactor of a number of civic organizations in both New York City and the Virgin Islands. With respect to the former, he has been a major contributor to the Robin Hood Foundation, whose purpose is to target poverty in New York City by finding, funding, and partnering with the most effective poverty fighting programs to maximize results. In the Virgin Islands, \_Jeffrey has donated money to literally dozens of civic organizations in need. These have included educational, sports, environmental, governmental, crisis intervention, children's advocacy and women's groups. One noteworthy example is the Antilles School in St which in 2005 recognized Jeffrey's generosity in assisting 27 students from 24 families to attend the school who otherwise would not have been able to. Perhaps the most unique area of Jeffrey's philanthropy is his no-strings attached support of scientists and mathematicians who are conducting "bleeding edge" research. As previously noted, Jeffrey has always had a deep interest in mathematics and science, and is particularly attracted to research which focuses on the mathematical foundation of life. By his own admission, he actively searches out scientists who are in the forefront of such research, enjoys meeting and talking with them, and often supports their research financially with the only proviso that they keep doing what they are doing. One example of this is **Interfed** of the Santa Fe Institute, the Nobel Prize winning physicist who predicted the existence of the quark and who later collaborated with colleagues at the institute on what has become known as Chaos Theory. Another particular example is A. Nowak, Ph.D., Director of the Program for Evolutionary Dynamics at Harvard University. Dr. Nowak recently wrote: > Over the years Jeffrey has taken a great interest in my research work, which deals with a mathematical description of biological processes. I have had many fruitful discussions with him. Often he would ask questions, which are surprising for me. Often I feel that none of my scientific colleagues would have asked that question, because we are too engaged in our own narrow perspective. Jeffrey's questions and proposals are highly original and always surprising. Many of his questions and ideas have led to highly successful research projects. For example, many years ago Jeffrey asked me about group selection, which led me to the discovery of the first precise mathematical theory of that topic. A bit later Jeffrey made me think about interaction networks between people. The result was 'evolutionary graph theory', which is new field of mathematical biology. Most recently, Jeffrey discussed with me complicated ideas about the origin of life and the transition from chemistry to biology. The discussion also resulted in a highly successful and completely new research project. ... > Jeffrey has also financially supported my research projects. He has donated \$500,000 to the Institute for Advanced Study in Princeton, where I have worked as Head of Theoretical Biology from 1998 until 2003. In 2003, Jeffrey donated \$6,500,000 to Harvard University, where I work as Director of the Program for Evolutionary Dynamics and Professor of Mathematics and Biology. Both donations were meant to support my basic research work without any strings attached. Generosity to Employees and Others. While it might be commonplace to say that a particular business person treats his employees as family, Jeffrey's history clearly reflects this fact on both financial and emotional levels. Jeffrey is a wealthy man who is quick to share his largesse. But he is also a man who engages personally and emotionally those who work for him and those he knows. Once he learns of and determines through conversation a need or an aspiration of an employee, he explores this with the employee, treats it in almost mathematical terms as a problem in search of a solution, and then sees to it that, without strings attached, the solution happens. The issues may be accommodations that an employee needs to address pressing personal or family problems; tuition payments that an employee or employee family member needs to better himself or herself; or assistance, both financial and professional, an employee needs to address the vexing and often tragic problems that life presents human beings. In this capacity, he is a benefactor but quite often also a mentor. Examples abound. One particularly poignant one was recounted by Darren K. Indyke, general counsel to Jeffrey: Two years ago, a building workman approached Jeffrey with news that the workman's wife needed a kidney transplant and that the workman's sisterin-law was a willing donor. Unfortunately, the sister-in-law was a citizen of Colombia and the workman did not have the financial resources or know how to get the sister-in-law into the country for the surgery. Jeffrey arranged for immigration counsel to expedite a visa for the sister-in-law and sponsored and purchased the plane tickets for the sister-in-law's visit to the United States. The surgery was a success and both patients recovered completely. The sister-in-law flew back to Colombia at Mr. Epstein's expense. Last year, the workman and his wife celebrated the high school graduation of their oldest daughter, whose college education is now being funded by Mr. Epstein. There have been many instances of accommodations Jeffrey has made for employees so that they could address significant issues of their personal lives. Several examples follow: > A father of one of Jeffrey's employees in the Virgin Islands was recently diagnosed with cancer. Jeffrey is personally paying the medical bills for the father's treatment and has given the employee financial support and complete flexibility to take time off from work whenever required in order to fly to Florida to attend to the employee's father. Lesley Groff, a personal assistant to Jeffrey, reported a number of accommodations Jeffrey has made, i.e., purchase of a vehicle for her commute, extended maternity leave, a reduced work week and permission to work from home, which have strengthened her family life. Lauren Kwintner, another New York City-based employee, told of accommodations from 2003 to 2005 that Jeffrey made for her to attend to her father, who had been diagnosed with multiple myeloma, at both Sloane Kettering Memorial Hospital and subsequently the Hospital for Joint Diseases, until his passing. Bella Klein, also a New York City-based employee, was a single mother whose son was accepted to Cornell University; Jeffrey has paid up to 70% of his tuition expenses; the son now has his Degree and is working on his Ph.D. Harry Beller, a sixteen-year employee, is an orthodox Jew who is required to be home prior to sundown on Fridays and on all Jewish holidays. Jeffrey has always accommodated his religious commitments, on occasion permitting pressing Friday transactions to take place on the following Monday. Mr. Beller also told of Jeffrey's assistance in making available any of his contacts in the medical field and to take any necessary time off when one of his sons was diagnosed with Retinoblastoma. Jeffrey has been especially generous in funding the educational pursuits of his employees (and their family members) as a way of assisting them to better themselves and achieve their full potential. Mr. Indyke has written that over the last six years, Jeffrey has funded literally hundreds of thousands of dollars in tuition assistance to many individuals (some of whom Jeffrey has no connection with whatsoever) from the preschool to the post-graduate levels. Mr. Beller, mentioned above, for example, has been the recipient of tuition assistance for all six of his children! Another employee, Emad **Mathematically**, who was hired by Jeffrey at a particularly trying time of his adult life, told of Jeffrey's sponsorship of his son's AAU baseball team and of the tuition assistance for his son: Jeffrey Epstein has paid out of his pocket my son's high school tuition for 2 years now totaling around \$20,000 and has given him the opportunity to get a top notch education at a private all boys catholic high school and my son has thrived in that environment and averaged a grade of 91 in his freshmen (sic) year and from all the travel baseball experience he was able to make the JV baseball team at one of the top schools in New Jersey. This has paved the way for my son to possibly have the opportunity to attend a college of his choice when the time comes. I would not have been able to [do] this if it wasn't for Mr. Epstein. Another example is that of a building worker named Philip whom Jeffrey is putting through vocational school in heating, refrigeration, and air conditioning. Mr. Indyke related that Jeffrey also takes time from his otherwise hectic schedule to meet with and mentor Mr. A final education example was related by David Lambert, an employee: While working late, after normal business hours, I have developed a relationship with the cleaning man who details our office space. Alfredo and I reflect life's issues and family matters as best [as] a Colombian and English speaking friend may, but it takes us deep and a look or gesture speaks louder than words at times. One night our sign language, broken English and Spanish went to the topic of his oldest daughter attending college. Alfredo told me how proud he is of her attending college. "Me daughter, she very, very happy." I could see the emotion in his eyes which led to the words spoken loudly, clearly, and emphatically "... because, Mister Jeffrey." After many such conversations with Alfredo it's clear to me he was angst ridden for his children, not being able to provide the dream of a college level education, his children aware and sad of such consequence, were whisked away instantly to an ethereal place by one man. This is what my provider, Jeffrey Epstein, does for people. If he is aware of human suffering he will act quickly, generously, and without thought. Then he will walk away. His goal has been achieved and a life's crisis avoided, human suffering eliminated. Jeffrey is also aware that tragedy is a part of the landscape that people have to face and address. When he learns of employees facing such life critical events, he brings the same virtues, i.e., empathy, a determination to identify and solve the problem, and generosity, which he uses in other areas of his life, to bear on the problem. Mr. Indyke faced one such problem, and his recollection of it is worth quoting at length: > Shortly after I began working for Jeffrey, I experienced a personal and unexpected tragedy. After five years of marriage, my wife and I learned that I was infertile and we could not have children in the traditional manner. The recommended treatment protocol required my wife and I to undergo prohibitively expensive in-vitro fertilization cycles, which we could not afford and which were not then covered by the company's medical insurance. > I meekly approached Jeffrey and asked him if it would be possible to drop my wife and me from the company's medical policy in exchange for a different one or cash payment. Puzzled by my request, Jeffrey naturally asked why. When I told him, he was visibly affected and without even a moment's consideration, he told me to go for treatment and send him the bills. Having been with Jeffrey only a few months, I was astounded by his generosity and hurried to my desk to call my wife to share the amazing news. In the days and weeks that followed, Jeffrey personally researched infertility issues and shared the results of his research with me. He identified the experts in the field to make sure that my wife and I were seeing the right people. He and I spoke often about these issues and the progress of our treatment cycle. Unfortunately, the first cycle ended up a failure. Though my wife and I were hesitant to ask him, Jeffrey insisted that we undergo another cycle at his expense. The second cycle resulted in a pregnancy which had to be terminated because of genetic defects in the fetus. My wife and I were devastated and once again Jeffrey offered emotional, as well as financial, support and encouraged us to proceed. When the third cycle failed and my wife was then diagnosed with infertility problems, Jeffrey met with me to go over my wife's and my options, which now included in-vitro fertilization with donor eggs, an even costlier endeavor. Jeffrey did not blink and insisted to pay for the treatments if my wife and I decided we were willing to proceed. He also helped us explore options of private adoption through an agency. We chose the former, which Jeffrey funded, while we also pursued the in-vitro/egg donor option at Jeffrey's expense. At the unsuccessful completion of our fourth cycle and a failed adoption attempt, my wife and I were at the end of our rope and did not want to continue. Without Jeffrey's support and stubborn daily encouragement we would not have. He even recruited his then girlfriend, Ghislaine Maxwell, to meet with us to offer assistance with local adoption and overseas adoption procedures and to encourage us to try again. Thankfully, after our fifth cycle, my wife and I were blessed with twin daughters. Although Jeffrey was adamant that we owed him nothing, Jeffrey honored us by agreeing to be the godfather of our children. The bottom line for Jeffrey Epstein is that while he has become an improbably successfully business man, he has also been an unusually understanding and generous human being. His generosity has taken many forms and has benefited many people, but has been primarily directed to employees and others he comes in contact with, educational institutions, "bleeding edge" scientific researchers, wellness organizations, and civic groups. His aim has been to improve the lives of individuals by helping them address life problems and reach their potential; to enable educational, wellness, and civic organizations to better achieve their respective purposes; and, to the kind of scientific research which might potentially benefit all of mankind. Finally, in his generosity, Jeffrey has sought nothing for himself. To the extent it is possible, his giving has always been anonymous; when this has not been possible, it is clear that he does not seek the spotlight for these acts.