Epstein emails

[admin]

https://oversightdemocrats.house.gov/ne ... ce-raising

https://oversightdemocrats.house.gov/si ... dacted.pdf

House committee on oversight

House oversight committee Releases Jeffrey Epstein Email Correspondence, Raising Questions About White House Coverup of Epstein Files
November 12, 2025
Press Release

This Tranche of Correspondence Raises Questions About Trump and Epstein’s Relationship, Trump’s Knowledge of Epstein’s Crimes and Relationship to Victims

Washington, D.C. — Today, Oversight Democrats and Ranking Member Robert Garcia released never-before-seen emails from the latest production from Jeffrey Epstein’s Estate, striking a blow against the White House’s Epstein cover-up. In private correspondence with Ghislaine Maxwell, Jeffrey Epstein wrote in 2011 that Donald Trump, “spent hours at my house” with a victim of sex trafficking, referring to Trump as “dog that hasn’t barked.” In a separate email with author Michael Wolff in 2019, Epstein stated explicitly that Donald Trump, “knew about the girls as he asked ghislaine to stop.” In another email with Wolff in 2015, Epstein and Wolff discuss if they can “craft an answer” for Trump’s upcoming CNN interview, with Wolff characterizing Epstein’s leverage over Donald Trump, saying, “If he says he hasn’t been on the plane or to the house, then that gives you a valuable PR and political currency.” The Epstein Estate released a total of 23,000 documents that the Oversight Committee is currently reviewing.

“The more Donald Trump tries to cover up the Epstein files, the more we uncover. These latest emails and correspondence raise glaring questions about what else the White House is hiding and the nature of the relationship between Epstein and the President,” said Ranking Member Robert Garcia. “The Department of Justice must fully release the Epstein files to the public immediately. The Oversight Committee will continue pushing for answers and will not stop until we get justice for the victims.”

The three emails from the production can be found below and here.

***

Email #1

Email #1 is direct correspondence between Jeffrey Epstein and Ghislaine Maxwell.

[x]
maxwell JE email 11.12

The correspondence reads:

To: Ghislaine Maxwell

From: Jeffrey Epstein

“I want you to realize that that dog that hasn’t barked is trump.. [Victim] spent hours at my house with him ,, he has never once been mentioned. Police chief. etc. im 75 % there

To: Jeffrey Epstein

From: Ghislaine Maxwell

“I have been thinking about that…”

Email #2

Email #2 is direct correspondence between Jeffrey Epstein and Michael Wolff.

[x]

The correspondence reads:

To: Michael Wolf

From: Jeffrey Epstein

“[Victim] mara lago. [identifier]. Trump said he asked me to resign, never a member ever. Of course he knew about the girls as he asked ghislaine to stop”

Email #3

Email #3 is direct correspondence between Jeffrey Epstein and Michael Wolff.

[x]
wolff 2 11.12

The correspondence reads:

To: Jeffrey Epstein

From: Michael Wolff

“I hear CNN planning to ask Trump tonight about his relationship with you--either on air or in scrum afterwards.

To: Michael Wolff

From: Jeffrey Epstein

“if we were able to craft an answer for him, what do you think it should be?”

To: Jeffrey Epstein

From: Michael Wolff

“I think you should let him hang himself. If he says he hasn't been on the plane or to the house, then that gives you a valuable PR and political currency. You can hang him in a way that potentially generates a positive benefit for you, or, if it really looks like he could win, you could save him, generating a debt. Of course, it is possible that, when asked, he'll say Jeffrey is a great guy and has gotten a raw deal and is a victim of political correctness, which is to be outlawed in a Trump regime.”

###

Subcommittees
119th Congress
Issues: Administration Congress Department of Justice

[admin]

https://oversight.house.gov/release/ove ... documents/

Oversight Committee Releases Additional Epstein Estate Documents

WASHINGTON—The House Committee on Oversight and Government Reform released an additional 20,000 pages of documents received from the estate of Jeffrey Epstein. The documents can be found here. https://drive.google.com/drive/u/0/mobi ... sp=sharing

A backup of the documents can be found here. https://www.dropbox.com/scl/fo/9bq6uj0p ... jaath&dl=0

[admin]

https://x.com/kylegriffin1/status/1988645521133871296

From: jeffrey E. <[email protected]
Sent: 8/23/2018 3:16:47 PM
To: Kathy Ruemmier [DELETE]
Subject: Re: NYTimes: Donald Trump's High Crimes and Misdemeanors

you see , i know how dirty donald is. my guess is that non lawyers ny biz people have no idea. what it means to have your fixer flip

On Thu, Aug 23, 2018 at 11:13 AM, Kathy Ruemmier <[DELETE]> wrote:
It makes no difference whether it was his money. Issue is failure to disclose. Plus, fact that he has lied his ass off about it makes clear that he knew it was illegal.

On August 23, 2018, at 11:03 AM, jeffrey E. <[email protected] wrote:

I think he makes the argument that it was his , trumps money , making it not illegal. though he also said he only found out afterwards? and the fact according to the indicment was billed as services rendered and grossed up. im sure his acct has flipped anyway. . I did talk in detail to starr yesterday re indicments how trump can make a deal ( special counsel) . clintons trash can yes starr gave me more. i YECHHHH!.

On Thu, Aug 23, 2018 at 10:50 AM, Kathy Ruemmler <[DELETE]> wrote:
Here's a story from The New York Times that I thought you'd find interesting:

The principled case for impeachment is clear. What's missing is the courage.

Read More...

Get The New York Times on your mobile device

--

please note
The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication is error, please notify us immediately by return e-mail or by e-mail to <[email protected] and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved

-
please note

[admin]

Epstein Estate Documents - Batch 7

https://www.dropbox.com/scl/fo/9bq6uj0p ... jaath&dl=0
DATA
IMAGES
NATIVES
TEXT

https://www.dropbox.com/scl/fo/9bq6uj0p ... tracking=1
TEXT
001
002

https://www.dropbox.com/scl/fo/9bq6uj0p ... tracking=1
001

Name
Modified
Size
2 days ago 9.2 KB
2 days ago 127.15 KB
2 days ago 13.01 KB
2 days ago 77.98 KB
2 days ago 36.08 KB
2 days ago 226.86 KB
2 days ago 22.73 KB
2 days ago 22.52 KB
2 days ago 6.35 KB
2 days ago 36.87 KB
2 days ago 10.7 KB
2 days ago 506.78 KB
2 days ago 37.15 KB
2 days ago 449.28 KB
2 days ago 290.6 KB
2 days ago 5.76 KB
2 days ago 7.11 KB
2 days ago 53.74 KB
2 days ago 279.35 KB
2 days ago 13.72 KB
2 days ago 1.06 MB
2 days ago 3.45 KB
2 days ago 1.04 KB
2 days ago 230.2 KB
2 days ago 17.96 KB
2 days ago 6.67 KB
2 days ago 112.17 KB
2 days ago 890 bytes
2 days ago 58.22 KB
2 days ago 13.92 KB
2 days ago 168.96 KB
2 days ago 613.25 KB
2 days ago 4.34 KB
2 days ago 25.47 KB
2 days ago 24.99 KB
2 days ago 22.42 KB
2 days ago 8.35 KB
2 days ago 5.1 KB
2 days ago 14.96 KB
2 days ago 27.93 KB
2 days ago 22.38 KB
2 days ago 20.04 KB
2 days ago 467.23 KB
2 days ago 1.04 KB
2 days ago 0.95 MB
2 days ago 5.36 KB
2 days ago 49.23 KB
2 days ago 165.08 KB
2 days ago 5.15 KB
2 days ago 26.68 KB
2 days ago 50.77 KB
2 days ago 5.11 KB
2 days ago 4.71 KB
2 days ago 3.95 KB
2 days ago 23.91 KB
2 days ago 24.06 KB
2 days ago 7.39 KB
2 days ago 46.08 KB
2 days ago 9.6 KB
2 days ago 17.57 KB
2 days ago 36.13 KB
2 days ago 594.9 KB
2 days ago 615.68 KB
2 days ago 127.33 KB
2 days ago 52.48 KB
2 days ago 262.54 KB
2 days ago 3.2 KB
2 days ago 6.74 KB
2 days ago 224.35 KB
2 days ago 12.03 KB
2 days ago 32.43 KB
2 days ago 50.09 KB
2 days ago 34.54 KB
2 days ago 94.77 KB
2 days ago 126.14 KB
2 days ago 90.51 KB
2 days ago 1.99 KB
2 days ago 15.93 KB
2 days ago 4.44 KB
2 days ago 16.69 KB
2 days ago 287.39 KB
2 days ago 92.83 KB
2 days ago 34.59 KB
2 days ago 3.96 KB
2 days ago 53.6 KB
2 days ago 11.23 KB
2 days ago 43.21 KB
2 days ago 178.21 KB
2 days ago 14.23 KB
2 days ago 49.72 KB
2 days ago 4.29 KB
2 days ago 10.82 KB
2 days ago 9.11 KB
2 days ago 52.98 KB
2 days ago 176.92 KB
2 days ago 94.83 KB
2 days ago 111.67 KB
2 days ago 41.31 KB
2 days ago 42.19 KB
2 days ago 10.5 KB
2 days ago 501.92 KB
2 days ago 82.58 KB
2 days ago 86.62 KB
2 days ago 100.31 KB
2 days ago 77.14 KB
2 days ago 9.89 KB
2 days ago 4.9 KB
2 days ago 10.35 KB
2 days ago 635.02 KB
2 days ago 279.56 KB
2 days ago 403 bytes
2 days ago 33.28 KB
2 days ago 3.42 KB
2 days ago 560.56 KB
2 days ago 11.38 KB
2 days ago 109.01 KB
2 days ago 1.08 KB
2 days ago 6.71 KB
2 days ago 8.98 KB
2 days ago 218.01 KB
2 days ago 2.26 MB
2 days ago 842 bytes
2 days ago 53.18 KB
2 days ago 53.52 KB
2 days ago 4.65 KB
2 days ago 3.97 KB
2 days ago 3.05 KB
2 days ago 84.36 KB
2 days ago 3.05 KB
2 days ago 35.06 KB
2 days ago 53.18 KB
2 days ago 57.71 KB
2 days ago 4.65 KB
2 days ago 420 bytes
2 days ago 446 bytes
2 days ago 418.54 KB
2 days ago 655.13 KB
2 days ago 2.26 MB
2 days ago 563.08 KB
2 days ago 228.58 KB
2 days ago 173.62 KB
2 days ago 46.18 KB
2 days ago 6.39 KB
2 days ago 559.29 KB
2 days ago 143.04 KB
2 days ago 100.96 KB
2 days ago 1.11 MB
2 days ago 144.05 KB
2 days ago 1.62 KB
2 days ago 8 KB
2 days ago 218.05 KB
2 days ago 17.98 KB
2 days ago 18.89 KB
2 days ago 42.06 KB
2 days ago 124.15 KB
2 days ago 306.04 KB
2 days ago 202.1 KB
2 days ago 4.04 KB
2 days ago 46.76 KB
2 days ago 163 bytes
2 days ago 193 bytes
2 days ago 4.75 KB
2 days ago 523 bytes
2 days ago 44.3 KB
2 days ago 11.17 KB
2 days ago 2.72 KB
2 days ago 4.62 KB
2 days ago 266.93 KB
2 days ago 134.84 KB
2 days ago 172.87 KB
2 days ago 80.12 KB
2 days ago 2.48 KB
2 days ago 56.47 KB
2 days ago 69.64 KB
2 days ago 69.78 KB
2 days ago 55.42 KB
2 days ago 31.73 KB
2 days ago 641.02 KB
2 days ago 735.97 KB
2 days ago 5.68 KB
2 days ago 857 bytes
2 days ago 18.7 KB
2 days ago 76.14 KB
2 days ago 99.6 KB
2 days ago 72.5 KB
2 days ago 481.99 KB
2 days ago 3.63 KB
2 days ago 20.39 KB
2 days ago 5.26 KB
2 days ago 1.34 KB
2 days ago 160.53 KB
2 days ago 9.61 KB
2 days ago 13.34 KB
2 days ago 271 bytes
2 days ago 8.68 KB
2 days ago 1.3 KB
2 days ago 1.95 KB
2 days ago 6.39 KB
2 days ago 22.58 KB
2 days ago 267.05 KB
2 days ago 7.31 KB
2 days ago 1.82 KB
2 days ago 4.72 KB
2 days ago 5.59 KB
2 days ago 6.44 KB
2 days ago 7.28 KB
2 days ago 8.71 KB
2 days ago 9.56 KB
2 days ago 10.4 KB
2 days ago 10.99 KB
2 days ago 7.89 KB
2 days ago 10.18 KB
2 days ago 10.2 KB
2 days ago 7.43 KB
2 days ago 89.66 KB
2 days ago 17.79 KB
2 days ago 2.53 KB
2 days ago 4.52 KB
2 days ago 4.25 KB
2 days ago 101.04 KB
2 days ago 5.57 KB
2 days ago 14.75 KB
2 days ago 9.34 KB
2 days ago 2.85 KB
2 days ago 33.63 KB
2 days ago 5.81 KB
2 days ago 1.43 KB
2 days ago 10.6 KB
2 days ago 2.48 KB
2 days ago 2.46 KB
2 days ago 702.69 KB
2 days ago 8.68 KB
2 days ago 20.29 KB
2 days ago 40.15 KB
2 days ago 20.09 KB
2 days ago 4.9 KB
2 days ago 662 bytes
2 days ago 675.37 KB
2 days ago 13.79 KB
2 days ago 704.6 KB
2 days ago 8 KB
2 days ago 5.36 KB
2 days ago 6.46 KB
2 days ago 1.8 KB
2 days ago 554.95 KB
2 days ago 3.56 KB
2 days ago 5.94 KB
2 days ago 26.53 KB
2 days ago 7.76 KB
2 days ago 3.93 KB
2 days ago 461.59 KB
2 days ago 5.64 KB
2 days ago 4.44 KB
2 days ago 5.66 KB
2 days ago 7.95 KB
2 days ago 14.39 KB
2 days ago 8.4 KB
2 days ago 6.58 KB
2 days ago 94.83 KB
2 days ago 402.54 KB
2 days ago 6.21 KB
2 days ago 6.39 KB
2 days ago 1.67 KB
2 days ago 13.17 KB
2 days ago 17.27 KB
2 days ago 19.28 KB
2 days ago 445.96 KB
2 days ago 1.44 KB
2 days ago 4.67 KB
2 days ago 4.85 KB
2 days ago 2.13 KB
2 days ago 34.7 KB
2 days ago 36.83 KB
2 days ago 35.92 KB
2 days ago 163.28 KB
2 days ago 367.07 KB
2 days ago 60.47 KB
2 days ago 15.25 KB
2 days ago 14.33 KB
2 days ago 17.51 KB
2 days ago 2.33 KB
2 days ago 4.6 KB
2 days ago 9.43 KB
2 days ago 31.92 KB
2 days ago 36.48 KB
2 days ago 10.42 KB
2 days ago 32.77 KB
2 days ago 1.93 KB
2 days ago 4.27 KB
2 days ago 5.12 KB
2 days ago 6.17 KB
2 days ago 7.09 KB
2 days ago 2.05 KB
2 days ago 148.6 KB
2 days ago 2.86 KB
2 days ago 177.27 KB
2 days ago 104.6 KB
2 days ago 137.47 KB
2 days ago 1.68 KB
2 days ago 1.14 KB
2 days ago 4.95 KB
2 days ago 5.99 KB
2 days ago 7.74 KB
2 days ago 1.92 KB
2 days ago 4.82 KB
2 days ago 3.75 KB
2 days ago 4.11 KB
2 days ago 4.99 KB
2 days ago 7.42 KB
2 days ago 685 bytes
2 days ago 2.96 KB
2 days ago 6.58 KB
2 days ago 9.32 KB
2 days ago 7.58 KB
2 days ago 10.36 KB
2 days ago 10.38 KB
2 days ago 7.71 KB
2 days ago 20.42 KB
2 days ago 3.06 KB
2 days ago 4.24 KB
2 days ago 26.5 KB
2 days ago 3.81 KB
2 days ago 3.25 KB
2 days ago 4.83 KB
2 days ago 2.8 KB
2 days ago 10.46 KB
2 days ago 4.09 KB
2 days ago 3.51 KB
2 days ago 351.08 KB
2 days ago 10.04 KB
2 days ago 16.73 KB
2 days ago 33.51 KB
2 days ago 6.17 KB
2 days ago 3.26 KB
2 days ago 2.05 KB
2 days ago 17.59 KB
2 days ago 1.54 KB
2 days ago 22.8 KB
2 days ago 10.83 KB
2 days ago 80.15 KB
2 days ago 508 bytes
2 days ago 5.7 KB
2 days ago 3.93 KB
2 days ago 3.75 KB
2 days ago 29.83 KB
2 days ago 1,012 bytes
2 days ago 905 bytes
2 days ago 24.07 KB
2 days ago 6.94 KB
2 days ago 32.9 KB
2 days ago 33.42 KB
2 days ago 451.48 KB
2 days ago 45.96 KB
2 days ago 2.03 KB
2 days ago 3 KB
2 days ago 2.1 KB
2 days ago 2.96 KB
2 days ago 2.97 KB
2 days ago 3.73 KB
2 days ago 2.52 KB
2 days ago 3.39 KB
2 days ago 4.49 KB
2 days ago 21.76 KB
2 days ago 21.97 KB
2 days ago 23.08 KB
2 days ago 48.53 KB
2 days ago 48.53 KB
2 days ago 51.73 KB
2 days ago 8 KB
2 days ago 1.85 KB
2 days ago 3.6 KB
2 days ago 5.57 KB
2 days ago 7.36 KB
2 days ago 5.32 KB
2 days ago 7.05 KB
2 days ago 1.68 KB
2 days ago 2.67 KB
2 days ago 3.83 KB
2 days ago 73.51 KB
2 days ago 572 bytes
2 days ago 1.25 KB
2 days ago 3.32 KB
2 days ago 5 KB
2 days ago 3.68 KB
2 days ago 1.25 KB
2 days ago 2.75 KB
2 days ago 3.68 KB
2 days ago 3.68 KB
2 days ago 4.43 KB
2 days ago 2.25 KB
2 days ago 3.2 KB
2 days ago 2.7 KB
2 days ago 4.12 KB
2 days ago 5.24 KB
2 days ago 51.51 KB
2 days ago 44.98 KB
2 days ago 46.01 KB
2 days ago 8.98 KB
2 days ago 8.87 KB
2 days ago 4.39 KB
2 days ago 6.34 KB
2 days ago 2.46 KB
2 days ago 1.04 KB
2 days ago 1.32 KB
2 days ago 2.39 KB
2 days ago 3.37 KB
2 days ago 4.61 KB
2 days ago 46.52 KB
2 days ago 15.53 KB
2 days ago 5 KB
2 days ago 2.25 KB
2 days ago 293 bytes
2 days ago 1.33 KB
2 days ago 8.7 KB
2 days ago 8.32 KB
2 days ago 1.91 KB
2 days ago 8.69 KB
2 days ago 17.48 KB
2 days ago 2.21 KB
2 days ago 2.55 KB
2 days ago 2.57 KB
2 days ago 2.42 KB
2 days ago 2.44 KB
2 days ago 3.16 KB
2 days ago 3.41 KB
2 days ago 4.46 KB
2 days ago 5.7 KB
2 days ago 4.61 KB
2 days ago 4.49 KB
2 days ago 5.41 KB
2 days ago 1.01 KB
2 days ago 7.07 KB
2 days ago 10.29 KB
2 days ago 8.82 KB
2 days ago 804 bytes
2 days ago 5.09 KB
2 days ago 4.66 KB
2 days ago 5.4 KB
2 days ago 4.28 KB
2 days ago 5.19 KB
2 days ago 3.39 KB
2 days ago 3.13 KB
2 days ago 101.63 KB
2 days ago 2.48 KB
2 days ago 10.99 KB
2 days ago 601 bytes
2 days ago 14.59 KB
2 days ago 41.35 KB
2 days ago 2.32 KB
2 days ago 2.85 KB
2 days ago 2.92 KB
2 days ago 4.46 KB
2 days ago 12.76 KB
2 days ago 111.16 KB
2 days ago 3.71 KB
2 days ago 1.01 KB
2 days ago 4.39 KB
2 days ago 4.44 KB
2 days ago 290.35 KB
2 days ago 10.08 KB
2 days ago 290.13 KB
2 days ago 237.48 KB
2 days ago 2.38 KB
2 days ago 13.91 KB
2 days ago 1.72 KB
2 days ago 2.63 KB
2 days ago 3.03 KB
2 days ago 4.24 KB
2 days ago 3.35 KB
2 days ago 6.92 KB
2 days ago 3.86 KB
2 days ago 14.85 KB
2 days ago 3.28 KB
2 days ago 2.41 KB
2 days ago 2.21 KB
2 days ago 8.92 KB
2 days ago 50.19 KB
2 days ago 48.41 KB
2 days ago 42.57 KB
2 days ago 3.1 KB
2 days ago 1.67 KB
2 days ago 16.89 KB
2 days ago 5.71 KB
2 days ago 6.68 KB
2 days ago 15.1 KB
2 days ago 11.86 KB
2 days ago 4.07 KB
2 days ago 129.35 KB
2 days ago 6.23 KB
2 days ago 7.33 KB
2 days ago 8.24 KB
2 days ago 34.58 KB
2 days ago 6.33 KB
2 days ago 29.49 KB
2 days ago 48.9 KB
2 days ago 8.73 KB
2 days ago 187.61 KB
2 days ago 4.29 KB
2 days ago 6.96 KB
2 days ago 23.5 KB
2 days ago 475.3 KB
2 days ago 37.88 KB
2 days ago 351.78 KB
2 days ago 57.64 KB
2 days ago 14.34 KB
2 days ago 128.31 KB
2 days ago 12.76 KB
2 days ago 20.66 KB
2 days ago 38.82 KB
2 days ago 73.69 KB
2 days ago 31.68 KB
2 days ago 9.31 KB
2 days ago 31.13 KB
2 days ago 5.29 KB
2 days ago 11.93 KB
2 days ago 4.67 KB
2 days ago 35.12 KB
2 days ago 2.2 KB
2 days ago 171.08 KB
2 days ago 11.24 KB
2 days ago 39.19 KB
2 days ago 40.28 KB
2 days ago 41.4 KB
2 days ago 42.36 KB
2 days ago 505.29 KB
2 days ago 53.02 KB
2 days ago 13.31 KB
2 days ago 393.53 KB
2 days ago 255.75 KB
2 days ago 12.36 KB
2 days ago 96.51 KB
2 days ago 70.77 KB
2 days ago 47.42 KB
2 days ago 43.17 KB
2 days ago 70.01 KB
2 days ago 18.38 KB
2 days ago 1.02 KB
2 days ago 4.87 KB
2 days ago 16.72 KB
2 days ago 11.92 KB
2 days ago 12.72 KB
2 days ago 17.16 KB
2 days ago 2.19 KB
2 days ago 3.42 KB
2 days ago 4.3 KB
2 days ago 5.01 KB
2 days ago 6.01 KB
2 days ago 7.2 KB
2 days ago 1.74 KB
2 days ago 4.42 KB
2 days ago 6.57 KB
2 days ago 57.27 KB
2 days ago 4.14 KB
2 days ago 5.53 KB
2 days ago 6.86 KB
2 days ago 8.06 KB
2 days ago 9 KB
2 days ago 10.1 KB
2 days ago 10.1 KB
2 days ago 12.73 KB
2 days ago 3.11 KB
2 days ago 2.99 KB
2 days ago 1.07 KB
2 days ago 2.76 KB
2 days ago 6.17 KB
2 days ago 11.84 KB
2 days ago 11.84 KB
2 days ago 16.88 KB
2 days ago 22.98 KB
2 days ago 11.52 KB
2 days ago 10.92 KB
2 days ago 5.39 KB
2 days ago 5.89 KB
2 days ago 15.43 KB
2 days ago 19.97 KB
2 days ago 135.56 KB
2 days ago 1.47 KB
2 days ago 5.86 KB
2 days ago 959 bytes
2 days ago 43.36 KB
2 days ago 6.64 KB
2 days ago 32.89 KB
2 days ago 19.98 KB
2 days ago 5.94 KB
2 days ago 32.9 KB
2 days ago 3.16 KB
2 days ago 4.93 KB
2 days ago 21.62 KB
2 days ago 7.54 KB
2 days ago 5.44 KB
2 days ago 38.46 KB
2 days ago 3.03 KB
2 days ago 4.87 KB
2 days ago 16.86 KB
2 days ago 2.71 KB
2 days ago 3.05 KB
2 days ago 6.79 KB
2 days ago 17.34 KB
2 days ago 32.54 KB
2 days ago 36.03 KB
2 days ago 3.46 KB
2 days ago 4.28 KB
2 days ago 4.55 KB
2 days ago 5.39 KB
2 days ago 6.6 KB
2 days ago 7.34 KB
2 days ago 6.46 KB
2 days ago 4.18 KB
2 days ago 21 KB
2 days ago 1.58 KB
2 days ago 10.34 KB
2 days ago 114.64 KB
2 days ago 2.85 KB
2 days ago 1.78 KB
2 days ago 2.68 KB
2 days ago 5.88 KB
2 days ago 3.18 KB
2 days ago 4.32 KB
2 days ago 5.27 KB
2 days ago 6.58 KB
2 days ago 42.65 KB
2 days ago 5.81 KB
2 days ago 7.24 KB
2 days ago 5.99 KB
2 days ago 2.13 KB
2 days ago 2.94 KB
2 days ago 6.55 KB
2 days ago 6.72 KB
2 days ago 3.62 KB
2 days ago 53.46 KB
2 days ago 35.33 KB
2 days ago 6.58 KB
2 days ago 31.24 KB
2 days ago 32.68 KB
2 days ago 65.05 KB
2 days ago 2.42 KB
2 days ago 34.96 KB
2 days ago 28.57 KB
2 days ago 3.11 KB
2 days ago 9.63 KB
2 days ago 10.51 KB
2 days ago 11.32 KB
2 days ago 12.24 KB
2 days ago 13.02 KB
2 days ago 21.89 KB
2 days ago 1.11 KB
2 days ago 1.47 KB
2 days ago 8.88 KB
2 days ago 1.11 KB
2 days ago 333 bytes
2 days ago 2.9 KB
2 days ago 4.26 KB
2 days ago 14.44 KB
2 days ago 10.01 KB
2 days ago 10.9 KB
2 days ago 1.45 KB
2 days ago 1.8 KB
2 days ago 3.15 KB
2 days ago 13.69 KB
2 days ago 13.93 KB
2 days ago 15.14 KB
2 days ago 3.53 KB
2 days ago 4.3 KB
2 days ago 5.31 KB
2 days ago 3.11 KB
2 days ago 994 bytes
2 days ago 1.68 KB
2 days ago 3.11 KB
2 days ago 16.09 KB
2 days ago 18.02 KB
2 days ago 19.16 KB
2 days ago 4.15 KB
2 days ago 5.07 KB
2 days ago 5.21 KB
2 days ago 85.21 KB
2 days ago 7.27 KB
2 days ago 3.56 KB
2 days ago 1.67 KB
2 days ago 4.4 KB
2 days ago 5.29 KB
2 days ago 1.59 KB
2 days ago 2.14 KB
2 days ago 5.71 KB
2 days ago 1.49 KB
2 days ago 3.04 KB
2 days ago 3.3 KB
2 days ago 4.15 KB
2 days ago 5.09 KB
2 days ago 12.61 KB
2 days ago 14.12 KB
2 days ago 3.38 KB
2 days ago 7.59 KB
2 days ago 2.75 KB
2 days ago 2.04 KB
2 days ago 3.53 KB
2 days ago 10.63 KB
2 days ago 10.5 KB
2 days ago 11.46 KB
2 days ago 1.6 KB
2 days ago 1.91 KB
2 days ago 2.72 KB
2 days ago 1.83 KB
2 days ago 5.61 KB
2 days ago 6.71 KB
2 days ago 7.56 KB
2 days ago 7.71 KB
2 days ago 1.87 KB
2 days ago 2.7 KB
2 days ago 2.72 KB
2 days ago 3.54 KB
2 days ago 4.5 KB
2 days ago 5.29 KB
2 days ago 6.27 KB
2 days ago 6.36 KB
2 days ago 7.14 KB
2 days ago 7.13 KB
2 days ago 3.28 KB
2 days ago 4.09 KB
2 days ago 30.64 KB
2 days ago 997 bytes
2 days ago 230 bytes
2 days ago 935 bytes
2 days ago 3.19 KB
2 days ago 2.2 KB
2 days ago 973 bytes
2 days ago 2.87 KB
2 days ago 3.64 KB
2 days ago 4.47 KB
2 days ago 5.48 KB
2 days ago 6.52 KB
2 days ago 6.5 KB
2 days ago 7.45 KB
2 days ago 8.61 KB
2 days ago 9.44 KB
2 days ago 10.24 KB
2 days ago 10.25 KB
2 days ago 2.55 KB
2 days ago 3.75 KB
2 days ago 4.79 KB
2 days ago 5.84 KB
2 days ago 4.59 KB
2 days ago 592 bytes
2 days ago 1.55 KB
2 days ago 4.26 KB
2 days ago 8.9 KB
2 days ago 539 bytes
2 days ago 3.51 KB
2 days ago 2.05 KB
2 days ago 13.26 KB
2 days ago 385 bytes
2 days ago 1.58 KB
2 days ago 2.84 KB
2 days ago 2.93 KB
2 days ago 4.1 KB
2 days ago 5.11 KB
2 days ago 1.13 KB
2 days ago 1.94 KB
2 days ago 1.21 KB
2 days ago 2.09 KB
2 days ago 1.23 KB
2 days ago 15.47 KB
2 days ago 16.56 KB
2 days ago 8.06 KB
2 days ago 9.41 KB
2 days ago 1.79 KB
2 days ago 2.56 KB
2 days ago 10.85 KB
2 days ago 12.09 KB
2 days ago 315 bytes
2 days ago 1.11 KB
2 days ago 2.63 KB
2 days ago 3.41 KB
2 days ago 4.28 KB
2 days ago 238 bytes
2 days ago 4.92 KB
2 days ago 2.16 KB
2 days ago 2.32 KB
2 days ago 1.34 KB
2 days ago 18.91 KB
2 days ago 968 bytes
2 days ago 1.76 KB
2 days ago 1.11 KB
2 days ago 1.89 KB
2 days ago 1.03 KB
2 days ago 9.76 KB
2 days ago 9.78 KB
2 days ago 1 KB
2 days ago 1.12 KB
2 days ago 3.57 KB
2 days ago 4.64 KB
2 days ago 15.19 KB
2 days ago 841 bytes
2 days ago 4.77 KB
2 days ago 5.7 KB
2 days ago 2.51 KB
2 days ago 3.83 KB
2 days ago 2.08 KB
2 days ago 1.08 KB
2 days ago 14.76 KB
2 days ago 17.44 KB
2 days ago 18.72 KB
2 days ago 19.95 KB
2 days ago 19.95 KB
2 days ago 1.9 KB
2 days ago 6.41 KB
2 days ago 2.16 KB
2 days ago 2.24 KB
2 days ago 3.09 KB
2 days ago 12.5 KB
2 days ago 1.38 KB
2 days ago 2.38 KB
2 days ago 2.81 KB
2 days ago 2.73 KB
2 days ago 1.2 KB
2 days ago 1.77 KB
2 days ago 1.79 KB
2 days ago 948 bytes
2 days ago 1.32 KB
2 days ago 1.91 KB
2 days ago 4.06 KB
2 days ago 6.88 KB
2 days ago 1.73 KB
2 days ago 1.29 KB
2 days ago 2.96 KB
2 days ago 4.31 KB
2 days ago 2.8 KB
2 days ago 5.08 KB
2 days ago 1.07 KB
2 days ago 1.14 KB
2 days ago 2.11 KB
2 days ago 16.35 KB
2 days ago 16.35 KB
2 days ago 17.58 KB
2 days ago 11.17 KB
2 days ago 2.55 KB
2 days ago 1,019 bytes
2 days ago 5.84 KB
2 days ago 2.2 KB
2 days ago 1.59 KB
2 days ago 2.46 KB
2 days ago 1.75 KB
2 days ago 1 KB
2 days ago 8.67 KB
2 days ago 33.86 KB
2 days ago 10.77 KB
2 days ago 2.33 KB
2 days ago 895 bytes
2 days ago 762 bytes
2 days ago 25.19 KB
2 days ago 3.55 KB
2 days ago 3.01 KB
2 days ago 3.79 KB
2 days ago 2.62 KB
2 days ago 1.44 KB
2 days ago 34.67 KB
2 days ago 3.65 KB
2 days ago 499 bytes
2 days ago 5.74 KB
2 days ago 36.31 KB
2 days ago 8.62 KB
2 days ago 2.63 KB
2 days ago 1.79 KB
2 days ago 4.31 KB
2 days ago 1.96 KB
2 days ago 3.74 KB
2 days ago 3.53 KB
2 days ago 438 bytes
2 days ago 457 bytes
2 days ago 2.26 KB
2 days ago 530 bytes
2 days ago 1.18 KB
2 days ago 1.33 KB
2 days ago 430 bytes
2 days ago 1.4 KB
2 days ago 461 bytes
2 days ago 1.58 KB
2 days ago 2.5 KB
2 days ago 3.67 KB
2 days ago 1.82 KB
2 days ago 28.44 KB
2 days ago 3.34 KB
2 days ago 1.61 KB
2 days ago 290 bytes
2 days ago 18.66 KB
2 days ago 1.98 KB
2 days ago 431 bytes
2 days ago 966 bytes
2 days ago 6.84 KB
2 days ago 13.11 KB
2 days ago 485 bytes
2 days ago 1.32 KB
2 days ago 1.02 KB
2 days ago 1.76 KB
2 days ago 234 bytes
2 days ago 146 bytes
2 days ago 74.33 KB
2 days ago 31.88 KB
2 days ago 2.67 KB
2 days ago 4.6 KB
2 days ago 4.09 KB
2 days ago 977 bytes
2 days ago 10.25 KB
2 days ago 3.3 KB
2 days ago 9.19 KB
2 days ago 5.99 KB
2 days ago 27.8 KB
2 days ago 417 bytes
2 days ago 22.69 KB
2 days ago 510 bytes
2 days ago 386 bytes
2 days ago 9.46 KB
2 days ago 1.72 KB
2 days ago 25.15 KB
2 days ago 7.51 KB
2 days ago 4.76 KB
2 days ago 12.31 KB
2 days ago 411 bytes
2 days ago 9.82 KB
2 days ago 22.08 KB
2 days ago 2.32 KB
2 days ago 531 bytes
2 days ago 1.91 KB
2 days ago 3.6 KB
2 days ago 28.49 KB
2 days ago 1.19 KB
2 days ago 6.15 KB
2 days ago 6.08 KB
2 days ago 3.56 KB
2 days ago 35.08 KB
2 days ago 37.15 KB
2 days ago 2.28 KB
2 days ago 457 bytes
2 days ago 470 bytes
2 days ago 591 bytes
2 days ago 502 bytes
2 days ago 5.45 KB
2 days ago 206 bytes
2 days ago 902 bytes
2 days ago 54.6 KB
2 days ago 34.97 KB
2 days ago 4.02 KB
2 days ago 34.89 KB
2 days ago 4.84 KB
2 days ago 374 bytes
2 days ago 4.23 KB
2 days ago 11.53 KB
2 days ago 10.35 KB
2 days ago 9.12 KB
2 days ago 2.51 KB
2 days ago 3.42 KB
2 days ago 1.64 KB
2 days ago 1.15 KB
2 days ago 1.53 KB
2 days ago 1.84 KB
2 days ago 3.19 KB
2 days ago 4.22 KB
2 days ago 297 bytes
2 days ago 1.27 KB
2 days ago 3.28 KB
2 days ago 1.11 KB
2 days ago 2.5 KB
2 days ago 7.83 KB
2 days ago 3.44 KB
2 days ago 3.72 KB
2 days ago 2.82 KB
2 days ago 1.98 KB
2 days ago 985 bytes
2 days ago 4.25 KB
2 days ago 364 bytes
2 days ago 3.08 KB
2 days ago 9.72 KB
2 days ago 9.67 KB
2 days ago 273 bytes
2 days ago 1.15 KB
2 days ago 2.94 KB
2 days ago 4 KB
2 days ago 7.29 KB
2 days ago 48.98 KB
2 days ago 2.5 KB
2 days ago 4.83 KB
2 days ago 9.42 KB
2 days ago 7.4 KB
2 days ago 19.52 KB
2 days ago 22.12 KB
2 days ago 41 KB
2 days ago 4.51 KB
2 days ago 4.74 KB
2 days ago 5.55 KB
2 days ago 6.97 KB
2 days ago 16.81 KB
2 days ago 4.52 KB
2 days ago 1.94 KB
2 days ago 5.09 KB
2 days ago 2.62 KB
2 days ago 3.5 KB
2 days ago 16.78 KB
2 days ago 2.41 KB
2 days ago 3.62 KB
2 days ago 30.15 KB
2 days ago 25.71 KB
2 days ago 1.84 KB
2 days ago 791 bytes
2 days ago 14.15 KB
2 days ago 21.85 KB
2 days ago 10.03 KB
2 days ago 25.69 KB
2 days ago 4.48 KB
2 days ago 5.3 KB
2 days ago 26.99 KB
2 days ago 7.01 KB
2 days ago 7.15 KB
2 days ago 5.92 KB
2 days ago 7.55 KB
2 days ago 2.5 KB
2 days ago 4.79 KB
2 days ago 63.66 KB
2 days ago 23.37 KB
2 days ago 14.07 KB
2 days ago 21.33 KB
2 days ago 8.17 KB
2 days ago 7.04 KB
2 days ago 2.35 KB
2 days ago 10.09 KB
2 days ago 62.79 KB
2 days ago 4.99 KB
2 days ago 44.86 KB
2 days ago 1.01 KB
2 days ago 13.33 KB
2 days ago 15.8 KB
2 days ago 1.42 KB
2 days ago 14.22 KB
2 days ago 30.76 KB
2 days ago 1.2 KB
2 days ago 10.68 KB
2 days ago 2.85 KB
2 days ago 19.36 KB
2 days ago 1.52 KB
2 days ago 59.32 KB
2 days ago 1.06 MB
2 days ago 75.41 KB
2 days ago 49.89 KB
2 days ago 50.38 KB
2 days ago 126.3 KB
2 days ago 31.43 KB
2 days ago 63.25 KB
2 days ago 40.81 KB
2 days ago 30.73 KB
2 days ago 55.46 KB
2 days ago 31.06 KB
2 days ago 36.03 KB
2 days ago 28 KB
2 days ago 32.24 KB
2 days ago 65.13 KB
2 days ago 65.58 KB
2 days ago 8.54 KB
2 days ago 2.19 KB
2 days ago 417 bytes
2 days ago 314 bytes
2 days ago 3.5 KB
2 days ago 354 bytes
2 days ago 4.27 KB
2 days ago 4.57 KB
2 days ago 4.25 KB
2 days ago 211 bytes
2 days ago 1.55 KB
2 days ago 1.23 KB
2 days ago 21.33 KB
2 days ago 9.38 KB
2 days ago 9.21 KB
2 days ago 6.16 KB
2 days ago 1.6 KB
2 days ago 4.57 KB
2 days ago 7.5 KB
2 days ago 67.34 KB
2 days ago 20.09 KB
2 days ago 17.4 KB
2 days ago 14.19 KB
2 days ago 12.58 KB
2 days ago 248 bytes
2 days ago 100.85 KB
2 days ago 55.42 KB
2 days ago 70.01 KB
2 days ago 49.01 KB
2 days ago 9.42 KB
2 days ago 5.7 KB
2 days ago 4.97 KB
2 days ago 3.7 KB
2 days ago 3.44 KB
2 days ago 3.7 KB
2 days ago 3.22 KB
2 days ago 2.52 KB
2 days ago 9.79 KB
2 days ago 361 bytes
2 days ago 7.37 KB
2 days ago 764 bytes
2 days ago 908 bytes
2 days ago 4 KB
2 days ago 3.27 KB
2 days ago 12.35 KB
2 days ago 46.7 KB
2 days ago 42.12 KB
2 days ago 536 bytes
2 days ago 1.38 KB
2 days ago 1.45 KB
2 days ago 1.3 KB
2 days ago 1.46 KB
2 days ago 1.31 KB
2 days ago 1.94 KB
2 days ago 3.35 KB
2 days ago 4.53 KB
2 days ago 5.33 KB
2 days ago 6.26 KB
2 days ago 7.02 KB
2 days ago 8 KB
2 days ago 8.7 KB
2 days ago 1.89 KB
2 days ago 3.83 KB
2 days ago 4.9 KB
2 days ago 28.51 KB
2 days ago 6.61 KB
2 days ago 1.21 KB
2 days ago 2.27 KB
2 days ago 1.42 KB
2 days ago 6.07 KB
2 days ago 2.9 KB
2 days ago 4.38 KB
2 days ago 4.34 KB
2 days ago 4.2 KB
2 days ago 1.32 KB
2 days ago 8.03 KB
2 days ago 9.04 KB
2 days ago 10.71 KB
2 days ago 1.97 KB
2 days ago 2.02 KB
2 days ago 3.23 KB
2 days ago 6.83 KB
2 days ago 1.1 KB
2 days ago 6.07 KB
2 days ago 2.22 KB
2 days ago 2.33 KB
2 days ago 2.47 KB
2 days ago 6.38 KB
2 days ago 1.22 KB
2 days ago 1.66 KB
2 days ago 2.69 KB
2 days ago 7.73 KB
2 days ago 696 bytes
2 days ago 2.55 KB
2 days ago 4.43 KB
2 days ago 2.63 KB
2 days ago 3.88 KB
2 days ago 4.9 KB
2 days ago 5.01 KB
2 days ago 1.38 KB
2 days ago 2.26 KB
2 days ago 2.99 KB
2 days ago 1.12 KB
2 days ago 45.31 KB
2 days ago 46.14 KB
2 days ago 46.25 KB
2 days ago 1.5 KB
2 days ago 4.54 KB
2 days ago 1.81 KB
2 days ago 1.86 KB
2 days ago 2.73 KB
2 days ago 3.54 KB
2 days ago 1.43 KB
2 days ago 2.44 KB
2 days ago 3.38 KB
2 days ago 2.51 KB
2 days ago 1.86 KB
2 days ago 8.92 KB
2 days ago 8.92 KB
2 days ago 2.01 KB
2 days ago 3.13 KB
2 days ago 2.29 KB
2 days ago 6.22 KB
2 days ago 8.22 KB
2 days ago 7.58 KB
2 days ago 8.41 KB
2 days ago 9.26 KB
2 days ago 9.99 KB
2 days ago 10.78 KB
2 days ago 6.92 KB
2 days ago 1.72 KB
2 days ago 19.78 KB
2 days ago 2.08 KB
2 days ago 20.87 KB
2 days ago 3.12 KB
2 days ago 4.63 KB
2 days ago 6.96 KB
2 days ago 7.4 KB
2 days ago 8.52 KB
2 days ago 9.38 KB
2 days ago 1.16 KB
2 days ago 2.09 KB
2 days ago 895 bytes
2 days ago 2.29 KB
2 days ago 2.61 KB
2 days ago 3.05 KB
2 days ago 8.6 KB
2 days ago 2.58 KB
2 days ago 4.57 KB
2 days ago 966 bytes
2 days ago 1.88 KB
2 days ago 6.36 KB
2 days ago 2.1 KB
2 days ago 2.25 KB
2 days ago 4.9 KB
2 days ago 1.04 KB
2 days ago 4.58 KB
2 days ago 8.71 KB
2 days ago 9.82 KB
2 days ago 11.39 KB
2 days ago 2.73 KB
2 days ago 3.89 KB
2 days ago 2.07 KB
2 days ago 702 bytes
2 days ago 7.17 KB
2 days ago 2.02 KB
2 days ago 1.47 KB
2 days ago 2.58 KB
2 days ago 3.41 KB
2 days ago 1.95 KB
2 days ago 2.9 KB
2 days ago 918 bytes
2 days ago 2.28 KB
2 days ago 1.26 KB
2 days ago 2.16 KB
2 days ago 2.97 KB
2 days ago 2.65 KB
2 days ago 2.62 KB
2 days ago 3.69 KB
2 days ago 4.65 KB
2 days ago 1.66 KB
2 days ago 1.6 KB
2 days ago 2.1 KB
2 days ago 6.03 KB
2 days ago 1.03 KB
2 days ago 48.97 KB
2 days ago 23.29 KB
2 days ago 720 bytes
2 days ago 751 bytes
2 days ago 2.78 KB
2 days ago 9.63 KB
2 days ago 3.72 KB
2 days ago 4.2 KB
2 days ago 3.56 KB
2 days ago 11.25 KB
2 days ago 3.28 KB
2 days ago 732 bytes
2 days ago 761 bytes
2 days ago 919 bytes
2 days ago 964 bytes
2 days ago 4.27 KB
2 days ago 1.24 KB
2 days ago 27.86 KB
2 days ago 6.65 KB
2 days ago 648 bytes
2 days ago 4.01 KB
2 days ago 15.89 KB
2 days ago 15.89 KB
2 days ago 4.75 KB
2 days ago 5.24 KB
2 days ago 7.94 KB
2 days ago 4.02 KB
2 days ago 919 bytes
2 days ago 24.66 KB
2 days ago 239 bytes
2 days ago 356 bytes
2 days ago 6.34 KB
2 days ago 9.05 KB
2 days ago 18.8 KB
2 days ago 37.04 KB
2 days ago 792 bytes
2 days ago 484 bytes
2 days ago 386 bytes
2 days ago 217 bytes
2 days ago 2.3 KB
2 days ago 470 bytes
2 days ago 1.88 KB
2 days ago 9 KB
2 days ago 20.14 KB
2 days ago 1.09 KB
2 days ago 1.62 KB
2 days ago 4.71 KB
2 days ago 532 bytes
2 days ago 16.4 KB
2 days ago 6.92 KB
2 days ago 8.98 KB
2 days ago 10.32 KB
2 days ago 3.77 KB
2 days ago 7.4 KB
2 days ago 8.01 KB
2 days ago 13.96 KB
2 days ago 18.55 KB
2 days ago 839 bytes
2 days ago 1.46 KB
2 days ago 4.22 KB
2 days ago 5.62 KB
2 days ago 2.75 KB
2 days ago 3.8 KB
2 days ago 4.02 KB
2 days ago 1 KB
2 days ago 1.8 KB
2 days ago 3.76 KB
2 days ago 3.6 KB
2 days ago 2.77 KB
2 days ago 1.37 KB
2 days ago 2.17 KB
2 days ago 1.61 KB
2 days ago 4.98 KB
2 days ago 3.2 KB
2 days ago 3.44 KB
2 days ago 1.56 KB
2 days ago 367 bytes
2 days ago 1.13 KB
2 days ago 1.89 KB
2 days ago 5.05 KB
2 days ago 2.07 KB
2 days ago 7.46 KB
2 days ago 8.48 KB
2 days ago 1.72 KB
2 days ago 1.59 KB
2 days ago 1.17 KB
2 days ago 10.55 KB
2 days ago 54.43 KB
2 days ago 13.85 KB
2 days ago 19.47 KB
2 days ago 20.25 KB
2 days ago 1.03 KB
2 days ago 8.14 KB
2 days ago 9.74 KB
2 days ago 10.35 KB
2 days ago 65.36 KB
2 days ago 10.96 KB
2 days ago 19.4 KB
2 days ago 25.15 KB
2 days ago 25.43 KB
2 days ago 1.17 KB
2 days ago 65.36 KB
2 days ago 2.54 KB
2 days ago 2.3 KB
2 days ago 2.19 KB
2 days ago 2 KB
2 days ago 3.21 KB
2 days ago 15.21 KB
2 days ago 806 bytes
2 days ago 5.16 KB
2 days ago 1.06 KB
2 days ago 3.09 KB
2 days ago 2.01 KB
2 days ago 1.78 KB
2 days ago 884 bytes
2 days ago 9.07 KB
2 days ago 637 bytes
2 days ago 2.27 KB
2 days ago 46.67 KB
2 days ago 4.37 KB
2 days ago 5.41 KB
2 days ago 5 KB
2 days ago 5.04 KB
2 days ago 706 bytes
2 days ago 1.52 KB
2 days ago 7.23 KB
2 days ago 2.83 KB
2 days ago 2.11 KB
2 days ago 3.03 KB
2 days ago 3.56 KB
2 days ago 4.25 KB
2 days ago 5.08 KB
2 days ago 4.46 KB
2 days ago 2.42 KB
2 days ago 38.72 KB
2 days ago 46.12 KB
2 days ago 767 bytes
2 days ago 2.35 KB
2 days ago 3.24 KB
2 days ago 1.3 KB
2 days ago 10.37 KB
2 days ago 800 bytes
2 days ago 1.67 KB
2 days ago 2.51 KB
2 days ago 405 bytes
2 days ago 3.01 KB
2 days ago 1.92 KB
2 days ago 947 bytes
2 days ago 1.03 KB
2 days ago 1.48 KB
2 days ago 1.83 KB
2 days ago 1.82 KB
2 days ago 831 bytes
2 days ago 5.42 KB
2 days ago 6.52 KB
2 days ago 7.48 KB
2 days ago 1.89 KB
2 days ago 2.8 KB
2 days ago 1.34 KB
2 days ago 14.6 KB
2 days ago 14.47 KB
2 days ago 18.81 KB
2 days ago 2.78 KB
2 days ago 40.77 KB
2 days ago 48.88 KB
2 days ago 61.24 KB
2 days ago 6.75 KB
2 days ago 1.46 KB
2 days ago 1.8 KB
2 days ago 1.43 KB
2 days ago 7.4 KB
2 days ago 9.12 KB
2 days ago 8 KB
2 days ago 7.05 KB
2 days ago 7.84 KB
2 days ago 8.69 KB
2 days ago 9.45 KB
2 days ago 9.46 KB
2 days ago 10.34 KB
2 days ago 995 bytes
2 days ago 2.26 KB
2 days ago 3.1 KB
2 days ago 2.64 KB
2 days ago 3.38 KB
2 days ago 55.28 KB
2 days ago 13.52 KB
2 days ago 1.68 KB
2 days ago 26.53 KB
2 days ago 6.32 KB
2 days ago 7.25 KB
2 days ago 898 bytes
2 days ago 1.95 KB
2 days ago 1.71 KB
2 days ago 1.21 KB
2 days ago 5.45 KB
2 days ago 11.08 KB
2 days ago 10.27 KB
2 days ago 7.51 KB
2 days ago 4.66 KB
2 days ago 3.9 KB
2 days ago 1.27 KB
2 days ago 7.48 KB
2 days ago 15.35 KB
2 days ago 7.53 KB
2 days ago 18.08 KB
2 days ago 1.51 KB
2 days ago 49.24 KB
2 days ago 6.47 KB
2 days ago 32.73 KB
2 days ago 10.43 KB
2 days ago 7.52 KB
2 days ago 7.29 KB
2 days ago 3.66 KB
2 days ago 6.5 KB
2 days ago 3.29 KB
2 days ago 3.57 KB
2 days ago 3.96 KB
2 days ago 1.98 KB
2 days ago 2.91 KB
2 days ago 6.24 KB
2 days ago 6.17 KB
2 days ago 7.07 KB
2 days ago 1.48 KB
2 days ago 551 bytes
2 days ago 1.67 KB
2 days ago 784 bytes
2 days ago 6.88 KB
2 days ago 7.84 KB
2 days ago 1.66 KB
2 days ago 1.71 KB
2 days ago 1.57 KB
2 days ago 1.92 KB
2 days ago 3.94 KB
2 days ago 1.92 KB
2 days ago 1.92 KB
2 days ago 1.45 KB
2 days ago 1.58 KB
2 days ago 1.54 KB
2 days ago 864 bytes
2 days ago 6.87 KB
2 days ago 1.13 KB
2 days ago 1.9 KB
2 days ago 1.25 KB
2 days ago 1.65 KB
2 days ago 1.23 KB
2 days ago 877 bytes
2 days ago 2.35 KB
2 days ago 7.61 KB
2 days ago 884 bytes
2 days ago 941 bytes
2 days ago 1 KB
2 days ago 845 bytes
2 days ago 2.43 KB
2 days ago 9.96 KB
2 days ago 2.26 KB
2 days ago 2.79 KB
2 days ago 870 bytes
2 days ago 941 bytes
2 days ago 905 bytes
2 days ago 855 bytes
2 days ago 8.55 KB
2 days ago 7.68 KB
2 days ago 8.31 KB
2 days ago 10.02 KB
2 days ago 6.74 KB
2 days ago 1.3 KB
2 days ago 2.4 KB
2 days ago 310 bytes
2 days ago 313 bytes
2 days ago 5.77 KB
2 days ago 7.82 KB
2 days ago 1.8 KB
2 days ago 4.41 KB
2 days ago 2.92 KB
2 days ago 3.85 KB
2 days ago 3.82 KB
2 days ago 6.82 KB
2 days ago 7.64 KB
2 days ago 8.88 KB
2 days ago 7.83 KB
2 days ago 6.98 KB
2 days ago 7.71 KB
2 days ago 8.74 KB
2 days ago 9.29 KB
2 days ago 1.29 KB
2 days ago 1.29 KB
2 days ago 2.57 KB
2 days ago 1.65 KB
2 days ago 5.52 KB
2 days ago 1.22 KB
2 days ago 2 KB
2 days ago 3.14 KB
2 days ago 4.36 KB
2 days ago 4.23 KB
2 days ago 1.95 KB
2 days ago 5.48 KB
2 days ago 466 bytes
2 days ago 467 bytes
2 days ago 818 bytes
2 days ago 895 bytes
2 days ago 2.1 KB
2 days ago 1.09 KB
2 days ago 3.73 KB
2 days ago 3.33 KB
2 days ago 4.61 KB
2 days ago 3.16 KB
2 days ago 8.91 KB
2 days ago 7.71 KB
2 days ago 7.69 KB
2 days ago 70.71 KB
2 days ago 1.44 KB
2 days ago 959 bytes
2 days ago 1.06 KB
2 days ago 2.53 KB
2 days ago 1.44 KB
2 days ago 8.73 KB
2 days ago 8.5 KB
2 days ago 7.71 KB
2 days ago 7.84 KB
2 days ago 3.34 KB
2 days ago 4.27 KB
2 days ago 6.04 KB
2 days ago 6.08 KB
2 days ago 4.9 KB
2 days ago 5.46 KB
2 days ago 4.21 KB
2 days ago 4.34 KB
2 days ago 3.13 KB
2 days ago 2 KB
2 days ago 2.34 KB
2 days ago 1.44 KB
2 days ago 2.5 KB
2 days ago 3.21 KB
2 days ago 2.32 KB
2 days ago 2.29 KB
2 days ago 2.04 KB
2 days ago 3.39 KB
2 days ago 1.12 KB
2 days ago 4.08 KB
2 days ago 276 bytes
2 days ago 1.11 KB
2 days ago 1.34 KB
2 days ago 2.51 KB
2 days ago 2.19 KB
2 days ago 3.21 KB
2 days ago 4.04 KB
2 days ago 490 bytes
2 days ago 464 bytes
2 days ago 1.25 KB
2 days ago 2.21 KB
2 days ago 1.04 KB
2 days ago 1.95 KB
2 days ago 321 bytes
2 days ago 271 bytes
2 days ago 1.23 KB
2 days ago 3.36 KB
2 days ago 4.55 KB
2 days ago 5.38 KB
2 days ago 6.35 KB
2 days ago 6.39 KB
2 days ago 7.36 KB
2 days ago 4.89 KB
2 days ago 1.28 KB
2 days ago 2.42 KB
2 days ago 3.24 KB
2 days ago 1.57 KB
2 days ago 2.81 KB
2 days ago 3.71 KB
2 days ago 4.6 KB
2 days ago 6.15 KB
2 days ago 7.41 KB
2 days ago 4.43 KB
2 days ago 5.57 KB
2 days ago 339 bytes
2 days ago 1.58 KB
2 days ago 2.41 KB
2 days ago 392 bytes
2 days ago 1.37 KB
2 days ago 1.16 KB
2 days ago 2.07 KB
2 days ago 2.94 KB
2 days ago 281 bytes
2 days ago 1.55 KB
2 days ago 1 KB
2 days ago 1.22 KB
2 days ago 2.36 KB
2 days ago 2.26 KB
2 days ago 3.04 KB
2 days ago 394 bytes
2 days ago 1.1 KB
2 days ago 1.45 KB
2 days ago 2.28 KB
2 days ago 288 bytes
2 days ago 1.44 KB
2 days ago 2.29 KB
2 days ago 1.5 KB
2 days ago 1,013 bytes
2 days ago 1.38 KB
2 days ago 2.6 KB
2 days ago 4.38 KB
2 days ago 4.38 KB
2 days ago 2.21 KB
2 days ago 3.96 KB
2 days ago 1.79 KB
2 days ago 3.73 KB
2 days ago 1.08 KB
2 days ago 1.16 KB
2 days ago 2.08 KB
2 days ago 1.83 KB
2 days ago 1.81 KB
2 days ago 993 bytes
2 days ago 929 bytes
2 days ago 718 bytes
2 days ago 2 KB
2 days ago 3.11 KB
2 days ago 3.97 KB
2 days ago 3.79 KB
2 days ago 8.17 KB
2 days ago 4.49 KB
2 days ago 995 bytes
2 days ago 1.07 KB
2 days ago 1.09 KB
2 days ago 1.78 KB
2 days ago 1.06 KB
2 days ago 1.77 KB
2 days ago 3.8 KB
2 days ago 1.08 KB
2 days ago 1.19 KB
2 days ago 3.35 KB
2 days ago 2.96 KB
2 days ago 2.6 KB
2 days ago 2.13 KB
2 days ago 3.38 KB
2 days ago 3.36 KB
2 days ago 1.26 KB
2 days ago 208 bytes
2 days ago 22.61 KB
2 days ago 44.83 KB
2 days ago 2.78 KB
2 days ago 5.86 KB
2 days ago 14.14 KB
2 days ago 5.23 KB
2 days ago 17.16 KB
2 days ago 18.49 KB
2 days ago 37.16 KB
2 days ago 7.12 KB
2 days ago 1.41 KB
2 days ago 4.68 KB
2 days ago 1.52 KB
2 days ago 5.98 KB
2 days ago 3.73 KB
2 days ago 3.04 KB
2 days ago 1.1 KB
2 days ago 428 bytes
2 days ago 798 bytes
2 days ago 5.53 KB
2 days ago 2.48 KB
2 days ago 1.77 KB
2 days ago 1.46 KB
2 days ago 1.32 KB
2 days ago 371 bytes
2 days ago 367 bytes
2 days ago 2.41 KB
2 days ago 1.35 KB
2 days ago 2.62 KB
2 days ago 1.47 KB
2 days ago 3.06 KB
2 days ago 4.34 KB
2 days ago 6.19 KB
2 days ago 7.42 KB
2 days ago 8.77 KB
2 days ago 10.5 KB
2 days ago 8.7 KB
2 days ago 11.77 KB
2 days ago 35.17 KB
2 days ago 7.4 KB
2 days ago 2.62 KB
2 days ago 1.05 KB
2 days ago 1.77 KB
2 days ago 8.25 KB
2 days ago 8.22 KB
2 days ago 1.04 KB
2 days ago 1.19 KB
2 days ago 2.32 KB
2 days ago 3.46 KB
2 days ago 4.22 KB
2 days ago 4.72 KB
2 days ago 2.54 KB
2 days ago 2.46 KB
2 days ago 4.25 KB
2 days ago 7.53 KB
2 days ago 1.46 KB
2 days ago 3.51 KB
2 days ago 3.38 KB
2 days ago 1.35 KB
2 days ago 1.69 KB
2 days ago 6.17 KB
2 days ago 6.21 KB
2 days ago 6.3 KB
2 days ago 6.21 KB
2 days ago 5.66 KB
2 days ago 1.01 KB
2 days ago 2.28 KB
2 days ago 3.35 KB
2 days ago 6.97 KB
2 days ago 8.18 KB
2 days ago 8.23 KB
2 days ago 3.09 KB
2 days ago 886 bytes
2 days ago 1.14 KB
2 days ago 2.04 KB
2 days ago 3.2 KB
2 days ago 10.88 KB
2 days ago 5.49 KB
2 days ago 34.1 KB
2 days ago 1.33 KB
2 days ago 8.72 KB
2 days ago 8.23 KB
2 days ago 8.12 KB
2 days ago 3.34 KB
2 days ago 2.26 KB
2 days ago 2.39 KB
2 days ago 2.48 KB
2 days ago 5.74 KB
2 days ago 4.44 KB
2 days ago 6.2 KB
2 days ago 1.13 KB
2 days ago 3.71 KB
2 days ago 12.41 KB
2 days ago 5.52 KB
2 days ago 18.49 KB
2 days ago 5.8 KB
2 days ago 690 bytes
2 days ago 17.05 KB
2 days ago 1.04 KB
2 days ago 5.24 KB
2 days ago 1.08 KB
2 days ago 4.74 KB
2 days ago 1.09 KB
2 days ago 265 bytes
2 days ago 12.3 KB
2 days ago 14.78 KB
2 days ago 8.77 KB
2 days ago 11.52 KB
2 days ago 16.88 KB
2 days ago 14.61 KB
2 days ago 1.12 KB
2 days ago 5.9 KB
2 days ago 2.24 KB
2 days ago 1.11 KB
2 days ago 1,019 bytes
2 days ago 4.96 KB
2 days ago 2.21 KB
2 days ago 19.41 KB
2 days ago 987 bytes
2 days ago 2.55 KB
2 days ago 2.72 KB
2 days ago 442 bytes
2 days ago 1.52 KB
2 days ago 4.57 KB
2 days ago 3.42 KB
2 days ago 3.74 KB
2 days ago 3.81 KB
2 days ago 4.52 KB
2 days ago 8.06 KB
2 days ago 2.68 KB
2 days ago 2.63 KB
2 days ago 9.47 KB
2 days ago 394 bytes
2 days ago 9.39 KB
2 days ago 1.54 KB
2 days ago 4.45 KB
2 days ago 3.77 KB
2 days ago 16.53 KB
2 days ago 23.97 KB
2 days ago 34.2 KB
2 days ago 25.99 KB
2 days ago 16.63 KB
2 days ago 28.54 KB
2 days ago 5.4 KB
2 days ago 6.6 KB
2 days ago 6.43 KB
2 days ago 448 bytes
2 days ago 1.91 KB
2 days ago 26 bytes
2 days ago 4.55 KB
2 days ago 1.77 KB
2 days ago 1.96 KB
2 days ago 5.3 KB
2 days ago 7.12 KB
2 days ago 7.1 KB
2 days ago 1.1 KB
2 days ago 5.27 KB
2 days ago 853 bytes
2 days ago 1.11 KB
2 days ago 969 bytes
2 days ago 977 bytes
2 days ago 11.69 KB
2 days ago 376 bytes
2 days ago 6.04 KB
2 days ago 5.3 KB
2 days ago 4.06 KB
2 days ago 1.7 KB
2 days ago 1.95 KB
2 days ago 691 bytes
2 days ago 399 bytes
2 days ago 468 bytes
2 days ago 584 bytes
2 days ago 5.48 KB
2 days ago 6.87 KB
2 days ago 8.81 KB
2 days ago 32.15 KB
2 days ago 582 bytes
2 days ago 7.82 KB
2 days ago 7.91 KB
2 days ago 7.73 KB
2 days ago 3.54 KB
2 days ago 7.04 KB
2 days ago 7.87 KB
2 days ago 7.87 KB
2 days ago 1.34 KB
2 days ago 855 bytes
2 days ago 2.79 KB
2 days ago 3.54 KB
2 days ago 1.27 KB
2 days ago 1.23 KB
2 days ago 4.06 KB
2 days ago 7.57 KB
2 days ago 583 bytes
2 days ago 519 bytes
2 days ago 449 bytes
2 days ago 7.86 KB
2 days ago 635 bytes
2 days ago 25.84 KB
2 days ago 1.11 KB
2 days ago 8.73 KB
2 days ago 1.96 KB
2 days ago 6.86 KB
2 days ago 718 bytes
2 days ago 1.56 KB
2 days ago 2.8 KB
2 days ago 4.85 KB
2 days ago 3.86 KB
2 days ago 6.87 KB
2 days ago 2.05 KB
2 days ago 2.22 KB
2 days ago 467 bytes
2 days ago 1.42 KB
2 days ago 1.1 KB
2 days ago 2.24 KB
2 days ago 15.59 KB
2 days ago 16.48 KB
2 days ago 1.92 KB
2 days ago 1.31 KB
2 days ago 9.3 KB
2 days ago 3.23 KB
2 days ago 4.18 KB
2 days ago 4.44 KB
2 days ago 5.63 KB
2 days ago 6.54 KB
2 days ago 8.14 KB
2 days ago 711 bytes
2 days ago 1.11 KB
2 days ago 1.94 KB
2 days ago 2.32 KB
2 days ago 2.84 KB
2 days ago 3.26 KB
2 days ago 4.17 KB
2 days ago 1.25 KB
2 days ago 1.77 KB
2 days ago 19.46 KB
2 days ago 1.94 KB
2 days ago 3.98 KB
2 days ago 1.34 KB
2 days ago 1.01 KB
2 days ago 1.19 KB
2 days ago 1.95 KB
2 days ago 3.8 KB
2 days ago 4.65 KB
2 days ago 1.09 KB
2 days ago 4.03 KB
2 days ago 1.23 KB
2 days ago 8.98 KB
2 days ago 3.77 KB
2 days ago 1.49 KB
2 days ago 1.87 KB
2 days ago 2.73 KB
2 days ago 44.46 KB
2 days ago 1.82 KB
2 days ago 1.86 KB
2 days ago 1.52 KB
2 days ago 1.64 KB
2 days ago 2.38 KB
2 days ago 2.29 KB
2 days ago 4.57 KB
2 days ago 3.58 KB
2 days ago 7.65 KB
2 days ago 2.03 KB
2 days ago 2.16 KB
2 days ago 2.12 KB
2 days ago 3.02 KB
2 days ago 1.13 KB
2 days ago 2.64 KB
2 days ago 4.1 KB
2 days ago 5.16 KB
2 days ago 6.33 KB
2 days ago 7.35 KB
2 days ago 1.66 KB
2 days ago 2.35 KB
2 days ago 1.99 KB
2 days ago 2.67 KB
2 days ago 4.84 KB
2 days ago 3.91 KB
2 days ago 3.97 KB
2 days ago 4.85 KB
2 days ago 866 bytes
2 days ago 2.88 KB
2 days ago 2.97 KB
2 days ago 1.1 KB
2 days ago 7.32 KB
2 days ago 956 bytes
2 days ago 1.82 KB
2 days ago 16.45 KB
2 days ago 4.99 KB
2 days ago 1.18 KB
2 days ago 1.34 KB
2 days ago 1.26 KB
2 days ago 1.19 KB
2 days ago 1.78 KB
2 days ago 3.88 KB
2 days ago 3.4 KB
2 days ago 10.1 KB
2 days ago 3.53 KB
2 days ago 3.36 KB
2 days ago 934 bytes
2 days ago 1.58 KB
2 days ago 9.97 KB
2 days ago 6.51 KB
2 days ago 356 bytes
2 days ago 716 bytes
2 days ago 1.85 KB
2 days ago 2 KB
2 days ago 1.86 KB
2 days ago 13.59 KB
2 days ago 1.3 KB
2 days ago 4.09 KB
2 days ago 432 bytes
2 days ago 4.21 KB
2 days ago 2.57 KB
2 days ago 1.87 KB
2 days ago 463 bytes
2 days ago 5.29 KB
2 days ago 3.97 KB
2 days ago 2.01 KB
2 days ago 5.3 KB
2 days ago 471 bytes
2 days ago 995 bytes
2 days ago 2.5 KB
2 days ago

[admin]

HOUSE_OVERSIGHT_010477
txt
https://www.dropbox.com/scl/fo/9bq6uj0p ... tracking=1

iiiIERFUL BILLIONAIRE,
- EX SCANDAL THAT UNDID HIM, AND ALL
THE JUSTICE THAT MONEY CAN BUY:
THE SHOCKING TRUE STORY OF JEFFREY EPSTEIN
HOUSE OVERSIGHT 010477
'TERSON
I don't see what it adds to the
.,,stigation had taken place, that
jut, at that time, no criminal
irs had been launched. And in
the rumors of Epstein's dealings
to be just that—rumors.
his lawyers, his editors, and his
ing odd and disturbing happened
:n in Times Square.
to the office early. He swiped his
the elevator button, and arrived in
ion area on the twenty-first floor.
ct time to review Ward's story.
n's town house—which is said to
residence in New York City at the
1, amid the flurry of menservants
and pristine white gloves, you feel
Leone's private Xanadu," she'd writ-
person's home, but a high-walled,
that seems to have no boundaries.
.ed not with paintings but with row
arned eyeballs; these, the owner tells
nported from England, where they
.rs. Next comes a marble foyer, which
e manner of Jean Dubuffet , .. but the
visitors who painted it. In any case,
150
One of the photographs
captured on video during the
Palm Beach Police Department
search warrant walk-through
of Epstein's El Brillo Way
residence (Palm Beach Police
Department)
Jeffrey Epstein, Coney Island,
circa 1969 (Anonymous)
Epstein's Palm Beach
property, 358 El Brill°
Way (O Chris Bott /
Splash News / Corbis)
Jeffrey Epstein's 1969 high school
yearbook photo (Lafayette High
School, Brooklyn, New York, 1969)
HOUSE OVERSIGHT 010478
Leslie Wexner, photographed
at his home in New York City,
1989 (CD Lynn Goldsmith)
(L to R) Jeffrey Epstein, Ghislaine
Maxwell, and Tony Randall, who
presided over a November 1991
YIVO Institute event at the Plaza
Hotel to honor the late Robert
Maxwell (Marina Gamier)
Jeffrey Epstein, Donald
Trump, and (newly signed
Trump Model)
attending the
Victoria's Secret Angels
party at Laura Belle club
in New York City on April
8, 1997 (Marina Gamier)
(L to R)
, Jeffrey Epstein,
Ghislaine Maxwell, and
attend a
reception at Mar-a-Lago,
1995. (Davidoff Studios)
HOUSE OVERSIGHT 010479
later, photographed
Le in New York City,
.ynn Goldsmith)
(L to R) Deborah
Blohm, Jeffrey Epstein,
Ghislaine Maxwell, and
Gwendolyn Beck attend a
reception at Mar-a-Lago,
1995. (Davidoff Studios)
age
fifteen; photo reportedly
taken by Jeffrey Epstein in
New York City
Affidavit, US
District Southern Court of
Florida)
(L to R) Prince Andrew,
and Ghislaine Maxwell; photo reportedly
taken by Epstein with camera
in Maxwell's London town house.
was seventeen years old at this
time. (r,iffidavit, US
District Southern Court of Florida.)
age seventeen;
photo reportedly taken by
Jeffrey Epstein at Zorro Ranch,
his New Mexico iDronerty.
in winter
Affidavit, US District Southern
Court of Florida)
Jeffrey Epstein with Professor
Alan Dershowitz in Cambridge,
MA, September 8, 2004 (0 Rick
Friedman / Corbis)
HOUSE OVERSIGHT 010480
On the day the police investigation
began, Epstein was photographed
with Ghislaine Maxwell in New York
City at the 2005 WaIl Street concert
series benefiting Wall Street Rising,
at Cipriani in New York City, March
15, 2005. (Joe Shildhorn / Patrick
McMullen)
Jeffrey Epstein, photographed
with attend-
ing the launch of Radar
magazine held at the Hotel
QT in New York City, May
2005 (Neil Rasmus / Patrick-
McMullan. com / Sipa Press)
2008 Palm Beach County Sheriff's Office
booking photo of Jeffrey Epstein (Palm
Beach County Sheriff's Office)
The Stockade, where Epstein
146 served his sentence, photog
1:1 here in 2006, was located a
Fairgrounds Road in West Pal
Beach, Florida. At the time,
used as a minimum- and in
security facility housing WO
,
juveniles, as well as male to
on a work-release program.
Aerial Photos)
HOUSE OVERSIGHT 010481
gation
-aphed
N York
oncert
Rising,
March
Patrick
vfullen)
Jeffrey Epstein, photographed
with Adrianna Ross, attend-
ing the launch of Radar
magazine held at the Hotel
QT in New York City, May
2005 (Neil Rasmus / Patrick-
McMullan.com / Sipa Press)
Ps Office
in (Palm
i's Office)
The Stockade, where Epstein
• served his sentence, photograph
here in 2006, was located at 673
• Fairgrounds Road in West Pal
Beach, Florida. At the time, it
used as a minimum- and media
security facility housing women
juveniles, as well as male Mina
on a work-release program. (5
Aerial Photos)
Epstein pleaded guilty to state
solicitation charges and served
thirteen months of an eighteen-
month sentence, with liberal
work-release privileges, in a
solitary cell at the Palm Beach
County Stockade similar to the
one pictured here, (Courtesy
CDC Special Management, Palm
Beach Sheriffs Office)
Jeffrey Epstein's entry in
the National Sex Offender
Registry (National Sex
Offender Registry)
Epstein and lawyer at the West
Palm Beach courthouse in June
2008 to enter a plea nearly two
years after being charged (Uma
Sanghvi / The Palm Beach Post /
ZUMAPRESS.com)
"IMF • MIMEO.
•••••komp
11.11111111
rio•
lidsammun
ta.1.1.13,÷7.60W31-4.
oak: 1
Epstein's Little Saint James
island, U.S. Virgin Islands: a
privately owned cay (nicknamed
• : Little Saint Jeff's) whose owner
locals affectionately refer to
as Richie Rich (© Chris Bott /
Splash News / Corbis)
HOUSE OVERSIGHT 010482
Epstein's Gulfstream,
photographed on Little
Saint James island in
the U.S. Virgin Islands,
January 2015 (0 Chris
Bott / Splash News I Corbis)
f.„-011-04.tr-
Epstein's longtime pilot, Larry Visos4
was at the controls as Epstein's
Gulfstream left Teterboro Airport in
New Jersey, January 2016. (Jae Donnelly)
When Prince Andrew and Epstein were seen
New York's Central
strolling together through 7-
Park in 2011, shortly after Epstein's release
from jail, the duke was forced to quit his
role as the British government's global trade ,
envoy. (Jae Donnelly / News of the World) —7
Stephen Hawking, photographed
in March 2006 aboard an Atlantis
submarine that was custom-fitted
by Epstein to accommodate his
wheelchair. Hawking was attendin2,
the conference "Confronting Gravin
"a workshop to explore fundanotii!
questions in physics and cosmolO•
sponsored by the J. Epstein VI
Foundation and the Center for
Education and Research in Cosra
and Astrophysics (CERCA) at Oic
Western Reserve University, at thz
Canton, St. Thomas, USVI. (Coterf.9
CERCA, Case Western LlniversitA.;:
Taglia.
°avies
?or
Ball.
HOUSE OVERSIGHT 010483
..•
Epstein's longtime pilot, Larry Visoski,
,
Iwas at the controls as Epstein's
Gulfstream left Teterboro Airport in
New Jersey, January 2016. (Jae Donnelly)
e seen
entral
elease
uit his
1 trade
World)
Stephen Hawking, photographed
in March 2006 aboard an Atlantis
submarine that was custom-fitted
by Epstein to accommodate his
wheelchair. Hawking was attending
•.4 the conference "Confronting Gravity.
"a workshop to explore fundamental
questions in physics and cosmoloo"
sponsored by the J. EpSteiti VI
Foundation and the Center for
Education and Research in Costnolop
and Astrophysics (CERCA) at Case
Western Reserve University, at the R;l1
Carlton, St. Thomas, LiSv). (Court0
CERCA, Case Western Univeis
Epstein's current residence, the
storied building formerly known
as the Herbert N. Straus Mansion,
on East list Street just off Central
Park, was acquired by Leslie
Wexner in 1989. (Laura Hanifin)
photographed at the New
lork Academy of Art's Tribeca
Ball, April 14, 2004 (Rob Rich /
SocietyAllure.com)
A framed photo of Florida governor
Charlie Crist and Scott Rothstein in
Rothstein's office in Fort Lauderdale,
autographed by Charlie Crist: Scott—
You are amazing! Charlie Crist
(CarlineJean 0 Sun Sentinel / ZUMA-
PRESS.com)
Epstein, a longtime benefactor, with
an unidentified friend, attended the
'IN 2014 New York Academy of Art's
Tribeca Ball, presented by Van Cleef
& Arpels, at the New York Academy
of Art on April 7, 2014, in New York
City. (Billy Farrell IBFAnyc.com)
HOUSE OVERSIGHT 010484
If. 0)
'1 re K V
UMW and husband,
NASCAR driver Brian Vickers,
arrive on the red carpet at the 141st
running of the Kentucky Derby
at Churchill Downs in Louisville,
Kentucky. (Jeff Moreland / Icon
Sportswire via AP Images)
and Larry
Visoski, Epstein's personal
pilot, in what appears to be
the cockpit of a Gulfstream
G-II (YouTube)
Michael and Janet Reiter at the Palm
Beach Police Foundation Policemen's
Ball at Mar-a-Lago, January
2012 (Debbie Schatz/ Palm Beach
Daily News / ZUMAPRESS.com)
Retired Palm Beach police
detective Joe Recarey,
November 2013 (Megltan
McCarthy / Palm Beach Daily
News f ZUMAPRES.S.com)
guests a
ture of a
The j
Mort Zu
Micros()
among I
several c
scientist
She'd ha
with Var
informal
to form t
In th
Wha
artist, hi
swipe hi
ter saw a
The
It wa
his office
Epstein
nal char
include
when he
She'd
one of hi
On doct(
HOUSE OVERSIGHT 010485

***

[admin]

***

HOUSE_OVERSIGHT_010486
txt
https://www.dropbox.com/scl/fo/9bq6uj0p ... tracking=1

7TERSON
I don't see what it adds to the
estigation had taken place, that
3ut, at that time, no criminal
Lirs had been launched. And in
the rumors of Epstein's dealings
I. to be just that—rumors.
his lawyers, his editors, and his
.in.g odd and disturbing happened
in Times Square.
to the office early. He swiped his
the elevator button, and arrived in
ion area on the twenty-first floor.
ct time to review Ward's story.
n's town house—which is said to
residence in New York City at the
amid the flurry of menservants
and pristine white gloves, you feel
Leone's private Xa-n.adu," she'd writ-
person's home, but a high-walled,
that seems to have no boundaries.
.ed not with paintings but with row
imed eyeballs; these, the owner tells
nported from England, where they
:Ts. Next comes a marble foyer, which
manner of Jean Dubuffet . . . but the
fisitors who painted it. In any case,
150
One of the photographs
captured on video during the
Palm Beach Police Department
search warrant walk-through
of Epstein's El Brillo Way
residence (Palm Beach Police
Department)
Jeffrey Epstein, Coney Island,
circa 1969 (Anonymous)
Epstein's Palm Beach
property, 358 El Brillo
Way (0 Chris Bott /
Splash News / Corbis)
Jeffrey Epstein's 1969 high school
yearbook photo (Lafayette High
School, Brooklyn, New York, 1969)
Leslie Wexner, photographed
at his home in New York City,
1989 (0 Lynn Goldsmith)
(L to R) Jeffrey Epstein, Ghislaine
Maxwell, and Tony Randall, who
presided over a November 1991
YIVO Institute event at the Plaza
Hotel to honor the late Robert
Maxwell (Marina Garnier)
(L to R) Deborah
Blohm, Jeffrey Epstein,
Ghislaine Maxwell, and
Gwendolyn Beck attend a
reception at Mar-a-Lago,
1995. (Davidoff Studios)
Jeffrey Epstein, Donald
Trump, and (newly signed
Trump Model) Ingrid
Seynhaeve, attending the
Victoria's Secret Angels
party at Laura Belle club
in New York City on April
8, 1997 (Marina Gamier)
txner, photographed
ne in New York City,
Lynn Goldsmith)
(L to R) Deborah
Blohm, Jeffrey Epstein,
Ghislaine Maxwell, and
Gwendolyn Beck attend a
reception at Mar-a-Lago,
1995. (Davidoff Studios)
Virginia Roberts, age
fifteen; photo reportedly
taken by Jeffrey Epstein in
New York City (Virginia
Roberts Affidavit, US
District Southern Court of
Florida)
(L to R) Prince Andrew, Virginia Roberts,
and Ghislaine Maxwell; photo reportedly
taken by Epstein with Roberts's camera
in Maxwell's London town house.
Roberts was seventeen years old at this
time. (Virginia Roberts Affidavit, .US
District Southern Court of Florida)
Virginia Roberts, age seventeen;
photo reportedly taken by
Jeffrey Epstein at Zorro Ranch,
his New Mexico property,
in winter (Virginia Roberts
Affidavit, US District Southern
Court of Florida)
Jeffrey Epstein with Professor
Alan Dershowitz in Cambridge,
MA, September 8, 2004 (0 Rich
Friedman / Corbis)
On the day the police investigation
began, Epstein was photographed
with Ghislaine Maxwell in New York
City at the 2005 Wall Street concert
series benefiting Wall Street Rising,
at Cipriani in New York City, March
15, 2005. (Joe Shildhorn / Patrick
McMullen)
Jeffrey Epstein, photographed
with Adrianna Ross, attend-
ing the launch of Radar
magazine held at the Hotel
QT in New York City, May
2005 (Neil Rasmus / Patrick-
McMullan.com / Sipa Press)
2008 Palm Beach County Sheriff's Office
booking photo of Jeffrey Epstein (Palm
Beach County Sheriff's Office)
The Stockade, where Epstein
served his sentence, photogra
here in 2006, was located at 6/
, Fairgrounds Road in West Palm
Beach, Florida. At the time, it
used as a minimum- and mediu
security facility housing wom
. juveniles, as well as male loins
on a work-release program.
Aerial Photos)
igation
,raphed
:w York
concert
Rising,
, March
'Patrick
Mullen)
Jeffrey Epstein, photographed
with Adrianna Ross, attend-
ing the launch of Radar
magazine held at the Hotel
QT in New York City, May
2005 (Neil Rasmus / Patrick-
McMullan.com / Sipa Press)
Ers Office
:in (Palm
Ts Office)
The Stockade, where Epstein
I served his sentence, photograph
here in 2006, was located at 673
Fairgrounds Road in West Palm
Beach, Florida. At the time, it vi
used as a minimum- and media
I security facility housing women
juveniles, as well as male ininat
on a work-release program. (s„
likki Aerial Photos)
Epstein pleaded guilty to state
solicitation charges and served —
thirteen months of an eighteen-
month sentence, with liberal
work-release privileges, in a
solitary cell at the Palm Beach
County Stockade similar to the
one pictured here. (Courtesy
CDC Special Management, Palm
Beach Sheriffs Office)
'J,
Epstein and lawyer at the West
Palm Beach courthouse in June
2008 to enter a plea nearly two
years after being charged (Uma
Sanghvi / The Palm Beach Post /
ZUMAPRESS.com)
Cr.pleara. of L. Le/rt.,. trn, ',ore eer
Jeffrey Epstein's entry in
the National Sex Offender
Registry (National Sex 11111=1,=====m1Immin
Offender Registry) 11.1101.111111.01=======
rt.
Itnnt
VA=
/et
Othalrer./Ir ani/feet
Ovarv.u.
nerar. Am err...,
erer,-,e. tar.< h /en •
ITT/. MYL.V.
Can Lae A.. Mr 11
Mee *VArsre/
41, rLa:
Epstein's Little Saint James
island, U.S. Virgin Islands: a
, privately owned cay (nicknamed
.41 Little Saint Jeffs) whose owner
locals affectionately refer to
as Richie Rich (0 Chris Bott /
Splash News / Corbis)
Epstein's Gulfstream,
photographed on Little
Saint James island in
the U.S. Virgin Islands,
January 2015 (0 Chris
Bott / Splash News / Corbis)
Epstein's longtime pilot, Larry Visoski
was at the controls as Epstein's
Gulfstream left Teterboro Airport in
New Jersey, January 2016. Jae Donne
When Prince Andrew and Epstein were seen
strolling together together through New York's Central --,-:-:,
—..
Park in 2011, shortly after Epstein's release
7`..-
-,
from jail, the duke was forced to quit his ."-:::" - role as as the British government's global trade
envoy. Uae Donnelly / News of the World)
if!
Stephen Hawking, photographed
in March 2006 aboard an Atlantis
submarine that was custom-fitted
by Epstein to accommodate his
wheelchair. Hawking was attending
the conference "Confronting Gra‘iiri
"a workshop to explore fundamental
questions in physics and cosinoto y.
sponsored by the J. Epstein Vi
Foundation and the Center for
Education and Research in Cosmc)
and Astrophysics (CERCA) at C
Western Reserve University, al.
Carlton, St. Thomas, USVI.
CERCA, Case Western University
, Taglizt
avies
Yor
Ball.
Epstein's longtime pilot, Larry Visoski,
was at the controls as Epstein's
Gulfstream left Teterboro Airport in
New Jersey, January 2016. (fete Donnelly)
:e seen
4 ,60
2entral
release
pit his -
L1 trade
World)
Stephen Hawking, photographed
in March 2006 aboard an Atlantis
submarine that was custom-fitted
by Epstein to accommodate his
wheelchair. Hawking was attending
the conference "Confronting GravitY:
"a workshop to explore fundamental
questions in physics and cosmologY.
sponsored by the J. Epstein VI
Foundation and the Center for
Education and Research in Cosmkg
and Astrophysics (CERCA) at Case,
Western Reserve University, at the A.! -
Carlton, St. Thomas, USVI. (Coot
CERCA, Case Western Unive1510
A framed photo of Florida governor
Charlie Crist and Scott Rothstein in
Rothstein's office in Fort Lauderdale,
autographed by Charlie Crist: Scott—
You are amazing! Charlie Crist
(Canine Jean © Sun Sentinel / ZUMA-
PRESS . com)
Epstein, a longtime benefactor, with
an unidentified friend, attended the
IN 2014 New York Academy of Art's
Tribeca Ball, presented by Van Cleef
& Arpels, at the New York Academy
of Art on April 7, 2014, in New York
City. (Billy Farrell / BFAnyc.com)
Epstein's current residence, the
storied building formerly known
as the Herbert N. Straus Mansion,
on East 71st Street just off Central
Park, was acquired by Leslie
Wexner in 1989. (Laura Hanifin)
Nadia Marcinkova, Michele
Tagliani, Sarah Kellen, and Teala
Davies, photographed at the New
York Academy of Art's Tribeca
Ball, April 14, 2004 (Rob Rich /
SocietyAllure.com)
Sarah (formerly Kellen/
Kensington) and husband,
NASCAR driver Brian Vickers,
arrive on the red carpet at the 141st
running of the Kentucky Derby
at Churchill Downs in Louisville,
Kentucky. (Jeff Moreland / Icon
FZ Sportswire via AP Images)
Nadia Marcinkova and Larry
Visoski, Epstein's personal
pilot, in what appears to be
the cockpit of a Gulfstream
G-II (YouTube)
Michael and Janet Reiter at the Palm
Beach Police Foundation Policemen's
Ball at Mar-a-Lago, January
2012 (Debbie Schatz / Palm Beach
Daily News / ZUMAPRESS.com)
Retired Palm Beach police
detective Joe Recarey,
November 2013 (Meghan
McCarthy / Palm Beach Daily
News / ZUMAPRESS.com)
guests a:
ture of a
The j
Mort Zu
Microso:
among I
several c
scientist
She'd ha
with Var
informal
to form
In th
Wha
artist, hi
swipe hi
ter saw a
The I
It wa
his offic(
Epstein
nal char
include
when he
She'd
one of hc
On docu
nerly Kellen/
:1) and husband,
[river Brian Vickers,
he red carpet at the 141st
the Kentucky Derby
11 Downs in Louisville,
(Jeff Moreland / Icon
via AP Images)
Michael and Janet Reiter at the Palm
Beach Police Foundation Policemen's
Ball at Mar-a-Lago, January
2012 (Debbie Schatz / Palm Beach
Daily News / ZUMAPRESS.com)
lice
rey,
,han
laity
om)
FILTHY RICH
guests are like pygmies next to the nearby twice-life-size sculp-
ture of a naked African warrior."
The journalist had confirmed that several prominent names—
Mort Zuckerman, the famous real estate mogul and publisher;
Microsoft executive Nathan Myhrvold; and Donald Trump
among them—had dined at the residence. She'd interviewed
several of Epstein's friends and ex-friends: Nobel Prize—winning
scientists, financiers who worked with Epstein at Bear Stearns.
She'd handled Steven Hoffenberg with aplomb. And, working
with Vanity Fair's editors, she'd figured out ways to slip even more
information between the lines, in ways that would allow readers
to form their own questions about Epstein's finances.
In that respect, she'd fulfilled her original assignment perfectly.
What Carter needed to figure out was what to do with the
artist, her sister, and their mother's story. But before he could
swipe his key card to let himself into the magazine's offices, Car-
ter saw a man standing in the reception area.
The man was motionless. He'd been waiting for Carter.
It was Jeffrey Epstein. Nonplussed, Carter invited him into
his office.
Epstein denied the claims involving underage women. No crimi-
nal charges had been filed. And so Vanity Fair decided not to
include the claims in Ward's article. But, according to Ward,
when her editor Doug Stumpf called her, she cried.
She'd worked so hard on the piece, gotten so stressed out that
one of her twins had begun to grow more slowly than the other.
On doctor's orders; she'd been put on bed rest.
151
JAMES PATTERSON
"Why?" she asked when she got to speak to Carter directly.
"He's sensitive about the young women. And we still get to
run most of the piece."
In her notebook, Ward wrote down the rest of what Carter
had said: "I believe him," he told her. "I'm Canadian."
But the piece that came out, in the March issue, still created a
sensation. It was called "The Talented Mr. Epstein" in a sly refer-
ence to Patricia Highsmith's celebrated suspense novel The Tal-
ented Mr. Ripley. The film adaptation, by Anthony Minghella, was
still fresh in the minds of Vanity Fair's readers. For Graydon
Carter, just posing the question Is Epstein some sort of scam artist,
like Ripley? had been question enough. And throughout the
piece, there were ironies readers wouldn't miss as they drew
their own conclusions about Epstein's life story. It came through
clearly in the first line of the last paragraph of Ward's 7,500-word
story: "Many people comment there is something innocent,
almost childlike about Jeffrey Epstein."
In context, the word innocent was rather ironic—so much so
that it almost became its own opposite.
752
Todd Meister: June 20_
Harry Cipriani, on
tion. The restaura
post of Harry's Bar
outpost in Venice. Locatei
it's a theme restaurant— t
hedge-fund manager name
wealthy man—Jeffrey Ep
father, Epstein's sometime
"I've known Jeffrey sir
let me tell you what I kr
everybody else says. First
and here's why—he has ril
that for him."
Meister knows how to ii
the son of a superrich fathe
TTERSON
got to speak to Carter directly.
mg women. And we still get to
down the rest of what Carter
her. "I'm Canadian."
in the March issue, still created a
lented Mr. Epstein" in a sly refer-
lebrated suspense novel The Tal-
lion, by Anthony Minghella, was
lity Fair's readers. For Graydon
Is Epstein some sort of scam artist,
n enough. And throughout the
ers wouldn't miss as they drew
)stein's life story. It came through
;t paragraph of Ward's 7,500-word
It there is something innocent,
Ei.pstein."
nt was rather ironic—so much so
)pposite.
152
CHAPTER 39
Todd Meister: June 2015
Harry Cipriani, on Fifth Avenue, is a New York institu-
tion. The restaurant began its life as an American out-
post of Harry's Bar—which was itself a famous American
outpost in Venice. Located inside the Sherry-Netherland hotel,
it's a theme restaurant—the theme being money. And today, a
hedge-fund manager named Todd Meister is talking about a very
wealthy man—Jeffrey Epstein—whom he knows through his
father, Epstein's sometime friend Bob Meister.
"I've known Jeffrey since I was nineteen," Meister says. "So
let me tell you what I know—whatever everyone knows and
everybody else says. First Off, he's no billionaire. Second off—
and here's why—he has no clue how to invest. He has people do
that for him."
Meister knows how to invest. He does it for other people and, as
the son of a superrich father, for himself. He also knows about the
153
71-
JAMES PATTERSON
good life. Parties in Vegas; weekends in the Hamptons; affairs with
beautiful women that end up getting splashed all over the tabloids.
It makes sense that, once upon a time, he and Epstein would
have gotten along.
"As for the girls," Meister says, "that was just business. He'd
seat them strategically at client dinners. When he went to the
movies, he'd take three or four girls with him. They'd take turns
massaging his back, arms, and legs."
According to Meister, Epstein used to boast that he "liked to
go into insane asylums because he liked to fuck crazy women."
"Who knows if it's true?" Meister adds. "But I'm telling you,
he used to say it."
From time to time, Epstein's friends and acquaintances would
see sides of Epstein that he'd grown much less shy about sharing.
Epstein encouraged Alan Dershowitz to invest with a prominent
hedge-fund manager named Orin Kramer. Dershowitz did, and he
made a lot of money at first. But in 2008, the fund Dershowitz had
invested in lost a substantial amount. Afterward, according to a for-
mer associate of Epstein's, Epstein appeared in Kramer's midtown
Manhattan office. There, sources say, he told Kramer: "It's very much
in your interest to make Alan Dershowitz whole."
Epstein's intervention worked, and Dershowitz recovered his
money.
To people who'd known Epstein back in the 1980s, this kind of
behavior was out of character. But the thing about Epstein was
that you never could figure him out. One minute he was charming.
154
FILT
The most charming man you'd
threat, and bluster. Somethini
numbers: this many parties, t
connection to Victoria's Secret,
Throw in the modeling ag
you plug in the parties. The SCE
But the thing is, Eyes Wide Shi
Epstein, getting on that plan
moment in Caddyshach — the c
out from his hole in the golf
Epstein was like the mole in a
a matter of time before he'd be
to ask yourself was, are peopl
als? Or are their morals like
shed (along with all the othe)
everyday working people have;
Eyes Wide Shut world?
Todd Meister, who was marri,
heiress Samantha Boardman
editorial director James Trurru
loud:
"How does a yutz like Epste
At Harry Cipriani, the ques
TERSON
ds in the Hamptons; affairs with
ig splashed all over the tabloids.
In a time, he and Epstein would
"that was just business. He'd
dinners. When he went to the
irls with him. They'd take turns
n used to boast that he "liked to
he liked to fuck crazy women."
eister adds. "But I'm telling you,
7iends and acquaintances would
)wn much less shy about sharing.
showitz to invest with a prominent
n Kramer. Dershowitz did, and he
in 2008, the fund Dershowitz had
punt. Afterward, according to a for-
An appeared in Kramer's midtown
say, he told Kramer: "It's very much
:rshowitz whole."
ced, and Dershowitz recovered his
:in back in the 1980s, this kind of.
But the thing about Epstein was
out. One minute he was charming.
154
FILTHY RICH
The most charming man you'd ever meet. The next he was snarl,
threat, and bluster. Something didn't add up. So you'd run the
numbers: this many parties, that many women. Even with the
connection to Victoria's Secret, the women didn't add up, either.
Throw in the modeling agency, it makes more sense. Then
you plug in the parties. The scene brings Eyes Wide Shut to mind.
But the thing is, Eyes Wide Shut only works in the shadows. For
Epstein, getting on that plane with Clinton was more like a
moment in Caddyshack — the one in which the groundhog peeks
out from his hole in the golf course. From there on in, Jeffrey
Epstein was like the mole in a game of whack-a-mole. It was only
a matter of time before he'd be caught. But the question you had
to ask yourself was, are people like Epstein born without mor-
als? Or are their morals like snakeskin—just something they
shed (along with all the other basic, day-to-day concerns that
everyday working people have) as they make their way into that
Eyes Wide Shut world?
Todd Meister, who was married to Nicky Hilton and stole the
heiress Samantha Boardman away from Conde Nast's former
editorial director James Truman, should know. He wonders out
loud:
"How does a yutz like Epstein get beautiful women?"
At Harry Cipriani, the question lingers in the air.
155
PART IV
The Investigation
CHAPTER 40
Michael Reiter: January 2006
1
As far as Michael Reiter's concerned, the case that his team
has built against Epstein—slowly, meticulously, over the
course of an entire year—is airtight. Even now, Detective
Recarey's finding new pieces of evidence. And already Reiter's
been laying the groundwork with prosecutors. State attorney
Barry Krischer has a reputation for toughness. He's known,
nationally, for his prosecution of juvenile offenders. And Reiter's
been keeping him abreast of the investigation. With Jeffrey
Epstein, it's not simply a matter of seeing him punished. It's a
matter of getting a sexual predator off the streets of Palm Beach.
Krischer assures the chief that he's taking this case very
seriously.
The state attorney's office will have Reiter's back at every
turn.
"I told him that we had an investigation that was very serious
159
JAMES PATTERSON
Detective Recarey: Feb,
IFor months, Joe Reca
been brought to Epsi
and car-rental records
according to a source withi;
would identify forty-seven
on El Brillo Way.
Recarey interviewed or
David Rogers, as well as Ep5.
He also spoke to a woman v
It turned out that Epste
actual Swedish deep-tissue]
for him and his friends, ti
them.
Did anything untoward
Epstein ever asked the worn;
that involved a very noteworthy person and that involved a num-
ber of underage females," Reiter would say in his deposition for
the suit that was later settled by Epstein. "That it was of a sexual
nature. I was concerned that we had not reached all of the vic-
tims, and we hadn't, I'm sure, at this point. I told him that I felt
like the suspect would probably become aware of the investiga-
tion at some point and that we should probably expect some con-
tact from.. . Mr. Epstein's lawyers. And I told him that I wanted
to keep him very well informed on this and that I hoped that he
would do the same. And that we would have to have more con-
tact in making sure it was handled responsibly, intelligently, and
appropriately as it moved forward."
Reiter would say that Epstein's name did not seem to ring a
bell with the state attorney. But shortly afterward, the chief
became aware that in certain powerful circles his investigation
was being looked upon unfavorably. "I had many people-related
conversations ... on the cocktail-party circuit that suggested we
approach this in a way that wasn't necessary," he would say.
Michael Reiter was a good cop. A good man. But he was about
to discover that when it came to men with the power and influ-
ence Epstein wielded, fairness under the law was a relative, mal-
leable concept.
160
A.TTERSON
• person and that involved a num-
r would say in his deposition for
p7 Epstein. "That it was of a sexual
ye had not reached all of the vic-
at this point. I told him that I felt
ly become aware of the investiga-
should probably expect some con-
Ters. And I told him that I wanted
:d on this and that I hoped that he
we would have to have more con-
idled responsibly, intelligently, and
yard."
teip's name did not seem to ring a
. But shortly afterward, the chief
powerful circles his investigation
yorably. "I had many people-related
tail-party circuit that suggested we
yasn't necessary," he would say.
J. cop. A good man. But he was about
le to men with the power and influ-
ss under the law was a relative, ma!-
160
CHAPTER 41
Detective Recarey: February 2006
IFor months, Joe Recarey's been interviewing girls who'd
been brought to Epstein's house, subpoenaing telephone
and car-rental records, conducting surveillance. Ultimately,
according to a source within the Palm Beach PD, the department
would identify forty-seven underage girls who'd been molested
on El Brillo Way.
Recarey interviewed one of Epstein's pilots, a man named
David Rogers, as well as Epstein's houseman, Alfredo Rodriguez.
He also spoke to a woman who really was a massage therapist.
It turned out that Epstein paid just one hundred dollars for
actual Swedish deep-tissue massages that the therapist provided
for him and his friends, the lawyer Alan Dershowitz among
them.
Did anything untoward ever happen? Recarey asked. Had
pstein ever asked the woman to rub his chest?
161
JAMES PATTERSON
No, she told him. She wasn't Epstein's type. The girls she'd
seen at his house were very thin and beautiful and did not have
tattoos. This massage therapist had several tattoos that were vis-
ible, and on quite a few occasions Epstein and Ghislaine Max-
well had made negative comments about them.
According to a Palm Beach Police Department Incident Report
filed by Recarey on July 25, 2006, the detective had also heard
from Mary's father, who said that a private eye had been to his
house, photographing his family and chasing visitors away.
Mary's dad had gotten the license plate—Florida E79-4EG.
Recarey traced it back to one Ivan Robles of West Palm Beach.
Robles turned out to be a licensed private investigator.
Recarey informed the state's attorney's office.
Alison also contacted Recarey and told him that she'd been
approached by someone who was in touch with Epstein. Alison
had been told that she'd receive money if she would refuse to
cooperate with the police.
Those who help him will be compensated, she was told,
according to Detective Recarey's incident report. "And those who
hurt him will be dealt with."
Recarey reassured the girl and told her that tampering with a
witness in a case like this was a serious, arrestable offense.
Then he told an assistant state attorney.
The detective was leaving no i undotted and no t uncrossed.
But he did wonder if the state attorney's office itself had
become part of the problem.
Barry Krischer: April
State attorney Barry l
before taking his post
in and around Palm
1992 and 1996, he had run
and 2004. During the coil
1970 with a three-year sti
Brooklyn, he received a m
from the Legal Aid Society
with the juvenile justice s)
protection team; the Peace
nor Jeb Bush, for his work'
time achievement award fi
member of the National D:
was not necessarily averse
In 2003, he launched an in
TERSON
Epstein's type. The girls she'd
and beautiful and did not have
ad several tattoos that were vis-
-is Epstein and Ghislaine Max-
:s about them.
rice Department Incident Report
6, the detective had also heard
a a private eye had been to his
and chasing visitors away.
ense plate —Florida E79-4EG.
[van Robles of West Palm Beach.
d private investigator.
attorney's office.
and told him that she'd been
ts in touch with Epstein. Alison
.-. money if she would refuse to
be compensated, she was told,
incident report. "And those who
id told her that tampering with a
serious, arrestable offense.
le attorney.
)i undotted and no t uncrossed.
state attorney's office itself had
162
CHAPTER 42
Barry Krischer: April 2006
State attorney Barry Krischer was an elected official, but
before taking his post, he'd been a lawyer in private practice
in and around Palm Beach. Elected twice to his office, in
1992 and 1996, he had run unopposed for state attorney in 2000
and 2004. During the course of his long career, which began in
1970 with a three-year stint in the district attorney's office in
Brooklyn, he received a number of awards: the pro bono award
from the Legal Aid Society of Palm Beach County for his service
with the juvenile justice system and for his work with the child
protection team; the Peace at Home award, presented by Gover-
nor jeb Bush, for his work with victims of family violence; a life-
time achievement award from the Florida Bar. He was a board
member of the National District Attorneys Association. And he
was not necessarily averse to going after the rich and powerful.
In 2003, he launched an investigation into Rush Limbaugh's use
163
JAMES PATTERSON
of, and means of obtaining, oxycodone and hydrocodone. (A few
years after Limbaugh's arrest, which coincided with Chief Reit-
er's investigation into Jeffrey Epstein, the talk-show host settled
with prosecutors, agreed to submit to random drug testing, and
gave up his firearms permit.)
Krischer himself, however, had been accused of sexual
misconduct.
In October of 1992, Jodi Bergeron, a legal secretary who'd worked
for Krischer, filed a sexual harassment lawsuit against him in the
Palm Beach County circuit court. That suit was dismissed, but a few
months later, the woman took Krischer to federal court, accusing
him of making unwanted advances and demanding recompense for
battery, negligence, invasion of privacy, and emotional distress.
Krischer had placed his hands, violently, inside her blouse,
the woman said. He'd forcibly fondled her breasts, forcibly kissed
her, and rubbed her shoulders while brushing her buttocks with
his hands and knees, all while accompanying the gestures with
verbal advances.
When she declined those advances, the woman claimed,
Krischer fired her.
Krischer denied the allegations. At the time, he was making his
first run for the state attorney's office. The charges were politically
motivated, he said. Members of a local chapter of NOW—the
National Organization for Women—had stood by the lawyer, cit-
ing his efforts to stop domestic violence, among his other virtues.
"I am here to support Barry Krischer for the work his office
did in my daughter's case," one woman said during a rally that
took place in front of the courthouse. "Her murderer received
the maximum sentence, a life sentence."
The second lawsuit had also been dismissed— after Krischer's
164
former law firm agreed
sand dollars in legal fees
Now Chief Reiter and D(
their own questions abc
wanted to charge Epsteil
behavior and four cour
minor—felony charges
behind bars in the case c
Kellen would be charged
This was not, the plai
for Jeffrey Epstein.
In cases involving tl.
attorneys tend to have s
But instead of granting I
the police that he would
asked to consider a broad
In a case such as Epst€
ing in and of itself. But v
only required in capital cas
may also be called in ci
involving crimes committ
wasn't a public official, an
cerned, the only controvet
that Epstein was rich an
B.B. vs. Epstein, Chief Reit(
ecutor had to make sure t
able doubt. And Krischer
of the young women who'c
1TERSON
FILTHY RICH
odone and hydrocodone. (A few
hich coincided with Chief Reit-
3tein, the talk-show host settled
nit to random drug testing, and
had been accused of sexual
n, a legal secretary who'd worked
sment lawsuit against him in the
That suit was dismissed, but a few
:rischer to federal court, accusing
es and demanding recompense for
ivacy, and emotional distress.
nds, violently, inside her blouse,
Indled her breasts, forcibly kissed
mhile brushing her buttocks with
accompanying the gestures with
advances, the woman claimed,
)fls. At the time, he was making his
office. The charges were politically
of a local chapter of NOW—the
ten—had stood by the lawyer, cit-
Tiolence, among his other virtues.
-y Krischer for the work his office
ie woman said during a rally that
irthouse. "Her murderer received
sentence."
o been dismissed—after Krischer's
164
former law firm agreed to pay Bergeron's attorney seven thou-
sand dollars in legal fees.
Now Chief Reiter and Detective Recarey were beginning to have
their own questions about Barry Krischer. The Palm Beach PD
wanted to charge Epstein with one count of lewd and lascivious
behavior and four counts of unlawful sexual activity with a
minor—felony charges that would have amounted to years
behind bars in the case of a conviction. Wendy Dobbs and Sarah
Kellen would be charged as accomplices.
This was not the plan that Krischer seemed to have in mind
for Jeffrey Epstein.
In cases involving the sexual abuse of minors, prosecuting
attorneys tend to have suspects arrested, then push for a trial.
But instead of granting his approval for an arrest, Krischer told
the police that he would convene a grand jury, which would be
asked to consider a broad range of charges.
In a case such as Epstein's, this was highly unusual. Not damn-
ing in and of itself. But very strange. In Florida, grand juries are
only required in capital cases. At the state attorney's discretion, they
may also be called in controversial cases—for instance, cases
involving crimes committed by public officials. But Jeffrey Epstein
wasn't a public official, and as far as the Palm Beach PD was con-
cerned, the only controversial thing about the case they'd built was
that Epstein was rich and well connected. In his deposition for
B.B. vs. Epstein, Chief Reiter rel ayed Krischer's concerns: the pros-
ecutor had to make sure that his case was solid, beyond a reason-
able doubt. And Krischer did have his doubts about the credibility
of the young women who'd be called to testify against Epstein.
165
JAMES PATTERSON
Even so, Reiter was beginning to wonder if Krischer was
stacking the deck in Epstein's favor—if, thanks to the sway
prosecutors have over grand juries, assembling such a jury
wasn't an excellent way to let Epstein off with the lightest pun-
ishment possible.
Another unusual thing: the way Barry Krischer and the law-
yers working for him ignored Chief Reiter's multiple phone calls
as well as Detective Recarey's— even though the police had been
hearing from Epstein's own lawyers.
"[Krischer] and I had an excellent relationship," Chief Reiter
said in his deposition. "I was the speaker at his swearing-in cere-
mony. And that he wouldn't return my phone calls—I mean, it
was clear to me by his actions that he could not objectively look
at this case."
In the incident report he ended up writing, Detective Recarey
remembered a phone call that he received from Guy Fronstin,
one of the lawyers representing Epstein.
It was a message Epstein wanted to send, something central to
the case that demanded explanation. The whole shit show swirling
around him was just a misunderstanding—a misrepresentation—
of Epstein's actual interests and intentions.
Fronstin says Mr. Epstein is very passionate about massages,
Detective Recarey would write.
And: Mr. Epstein had donated over $100,000 to the Ballet o
Florida for massages.
And: The massages are therapeutic and spiritually sound for
him. That is why he has had so many massages.
166
Palm Beach Police Delia?.
by Detective Joseph Reca
On April 13 and April 14, ;
eral occasions with ASA
Weiss and ASA ILanna_I B
victims needed to report for
were left on their voicemai
hours of 9:00 am and 11:30
Weiss and ASA Belohlavek
call as I had not heard from
the time and date of the Gra
At approximately 12:3(
ney's Office and Located
their offices. I entered ASA.
me that she was going to rei
an offer was made to the I
CTERSON
mg to wonder if Krischer was
favor —if, thanks to the sway
uries, assembling such a jury
)stein off with the lightest pun-
vay Barry Krischer and the law-
lief Reiter's multiple phone calls
even though the police had been
mrs.
ellent relationship," Chief Reiter
: speaker at his swearing-in cere-
urn my phone calls—I mean, it
hat he could not objectively look
d up writing, Detective Recarey
he received from Guy Fronstin,
Epstein.
n.ted to send, something central to
Lion. The whole shit show swirling
:standing—a misrepresentationitentions.
; very passionate about massages,
ted over $100,000 to the Ballet of
rapeutic and spiritually sound for
nany massages.
166
CHAPTER 43
Palm Beach Police Department Incident Report Filed
by Detective Joseph Recarey: July 25, 2006
On April 13 and April 14, 2006, I attempted contact on sev-
eral occasions with ASA [assistant state attorney Daliah]
Weiss and ASA [Latina] Belohlavek to ascertain when the
victims needed to report for Grand Jury testimony. Messages
were left on their voicemail. On April 17, 2006, during the
hours of 9:00 am and 11:30 am I again left messages for ASA
Weiss and ASA Belohlavek for either of them to return my
call as I had not heard from the State Attorney's Office as to
the time and date of the Grand Jury.
At approximately 12:30 pm, I went to the State Attor-
ney's Office and Located ASA Weiss and ASA Belohlavek in
their offices. I entered ASA Belohlavek's office who informed
me that she was going to return my call. She explained that
an offer was made to the Defense, Atty Guy Fronstin and
167
JAMES PATTERSON
Atty Alan Dershowitz. The offer is 1 count of Agg Assault
with intent to commit a felony, five years probation, with
adjudication withheld. Epstein would have to submit to psy-
chiatric/sexual evaluation and no unsupervised visits with
minors. When asked about all the other victims, ASA
Belohlavek stated that was the only offer made as to one vic-
tim, [Mary]. ASA Belohlaveles] cell phone rang and went to
voice mail. She checked her voice mail and played the mes-
sage on speaker. The caller identified himself as Atty Guy
Fronstin and acknowledged the deal made between them.
Fronstin stated in the message, he spoke with his client, Jef-
frey Epstein, and would agree to this deal. Fronstin asked to
call off the grand jury as they would accept this deal.
Belohlavek stated a probable cause would be needed to book
Epstein in the county Jail and would let me know as to when
it was needed. I explained my disapproval of the deal and not
being consulted prior to the deal being offered. However I
expressed that was only my opinion and the final approval
would come from the Chief of Police. She explained to have
Chief Reiter call Barry Krischer about the deal. I left the
area and returned to the police station where I briefed the
Chief about the deal offered.
I checked my voice mail messages and discovered a mes-
sage from [the] stepmother for the victim [Mary]. She was
calling because the State Attorney's Office still had not
returned any of her calls as to when they are needed for this
case. I then called ASA Belohlavek's office and left messages
for her to call the victims on this case and explain to them
what the State Attorney's Office had done.
168
Michael Reiter: May 2(
A plea offer?
Chief Reiter is o
sands of hours of wc
evidence. But instead of gob
see Epstein get off with a a
and a psych exam.
Why?
Alan Dershowitz has pre
pieces of evidence — printot
In her "About Me" colu
Mary has written "Ass and e
Under "Ever drank" an
"Yeah."
Under "Ever shoplifted":
Under "Ever skinny dipp,
TERSON
er is 1 count of Agg Assault
v, five years probation, with
would have to submit to psy-
no unsupervised visits with
all the other victims, ASA
only offer made as to one vic-
.1 cell phone rang and went to
,ice mail and played the mes-
lentified himself as Atty Guy
le deal made between them.
, he spoke with his client, Jef-
to this deal. Fronstin asked to
hey would accept this deal.
ause would be needed to book
would let me know as to when
iisapproval of the deal and not
deal being offered. However I
!pinion and the final approval
Police. She explained to have
:her about the deal. I left the
.ce station where I briefed the
tessages and discovered a mes-
)r the victim [Mary]. She was
ttorney's Office still had not
) when they are needed for this
lavek's office and left messages
this case and explain to them
ce had done.
168
CHAPTER 44
Michael Reiter: May 2006
A plea offer?
Chief Reiter is outraged. His team has logged thou-
sands of hours of work. They've assembled mountains of
evidence. But instead of going to trial, the state attorney wants to
see Epstein get off with a misdemeanor, five years of probation,
and a psych exam.
Why?
Alan Dershowitz has presented the prosecutors with his own
pieces of evidence—printouts from the victims' Myspace pages.
In her "About Me" column, under "Best physical feature,"
Mary has written "Ass and eyes."
Under "Ever drank" and "Ever smoked pot," she's written
"Yeah."
Under "Ever shoplifted": "Lots."
Under "Ever skinny dipped": "Yeah."
69
JAMES PATTERSON
Under "[Do] you wanna lose your virginity": "I already lost it."
One of the victims has been caught with drugs and arrested.
She's also been caught stealing from Victoria's Secret. From the
state attorney's perspective, these girls look like compromised
women. And if what they say about Epstein is true, wouldn't that
make them prostitutes?
As witnesses, they would be weak, while the lawyers on
Epstein's side were exceptionally strong.
Alan Dershowitz had represented Claus von Billow, the Brit-
ish socialite who was acquitted of the murder of his wife, Sunny.
Dershowitz had been on 0. J. Simpson's team when the former
football star was acquitted of the murders of his ex-wife, Nicole
Brown Simpson and Nicole's friend Ronald Lyle Goldman. And
rich as von Billow and Simpson had been, neither one had had
the resources that Epstein was willing and able to deploy in his
own defense.
Neither of them had been intimate friends with his lawyer.
As far as Reiter was concerned, none of that mattered. Even if
Epstein thought that the girls he'd molested were eighteen years
old—even if they had lied to him—it didn't matter under Flor-
ida law. The chief grew worried that in Epstein's case exceptions
were being made, and he grew even more concerned with each
unreturned call that he made to the state attorney's office.
On May 1, the Palm Beach PD asked the state attorney's office
to issue an arrest warrant for Jeffrey Epstein.
That same day, Chief Reiter took the extraordinary step of
writing Barry Krischer a letter all but demanding that he recuse
himself from the case.
170
TOWN OF
POLICE 13
A NATiONAL STMT. ACC1
PERSONAL AND CONFIDENTIAL
10, Barry E Krischer, State Attorney
Office of the State Attorney
;itteentit Judicial Circuit
401 North Dime Highway
West Patrn Beach. FL 33401
Dear Mr. Krischer.
Please find enclosed the probable cause
resulting from the Patm Beach PoLce Depa
Kellen and Haley Robson The. submissio
Assistam State Attoiney Latina ee!ohtdvef
Beach Police Department's presentation fc
I know That you agree that it •5 Our shared
oJtlic interest ay clis,:harg,ng cur outies er
odor observation to you that I coot:nue to he
II,t-, regreltob!e the! fOrce0
recent telephone calls to you and those of
have Peen unanswered and messages red
A'ter giv,ng th., much thought and consider
course that your office's handling of thin
sufhcient isason evistn tu rez,J.ro your Oa
:ases
Sir
Mit
Ch
MSR•nt
50,03.C.a.my RIO • Pas,•1 Reath. Fr.,* '00440 • t
TERSON
TOWN OF PALM BEACH
POLICE DEPARTMENT
A NATIONAL AM) STAT ACCREZrTE0 LAN,. ENFORaMENT ACZNCv
MaN. 4, 2006
PERSONAL AND CONFIDENTIAL
Mr Barry E Krischer, State Attorney
Office of the State Attorney
Fifteenth Judicial Circu,t
401 North Dixie 0-iighway
West Palm Beach, FL 33401
Dear Mr Krischer,
Prease find erclosed the probable cause attidavits and case filing packages thus far
resulting f,orn !he Palm Beach PoPce Department's in. estigaton of Jeffrey Epstem, Sarah
Kellen and Haley Robson The submission of these document:. are both in response to
Ast,stam State Attorney Lwzna 6e.oh.dv,k's re;quest fur triem anti to serve as the Palm
Beach Police Deoartrnent's presentation for prosecution
I know that you agree that it is OW shared responsibility to seek justice and to serve the
pittic trterest by dis,harging our outies r,th fairness ano accouritablity must rene,.... my
prior Observation to you that I ontrnve to find your office's treatment of these cases highly
urn.:-.uot 1 5 regrettable that! an forcao to communicate n this rranner tut my most
recent telephone calls to you and those of the lead detective to your assigned attorneys
have been uransi.vered and messages remain unreturned
.Mier giv.ng this much treJght and consideration I rrJst urge you to examine the unusual
course that your office's handling of this matter haS taken and consider 4 good and
suffcient Teaser, er.!stt, to reciJ,re your air cwrificat'on fro", tno prosecution of these
:ases.
Sincerely,
',U(AtaS 2f1,,Ta
Michel S. Reiter
Chef of Police
MSR-n:
4SSevtloCoamyRtio4 • P1•nfie.0F. 334104443 • 051111184W • FsiuSit; $3.-g,t'O•
Yur virginity": "I already lost it."
aught with drugs and arrested.
.om Victoria's Secret. From the
e girls look like compromised
at Epstein is true, wouldn't that
e weak, while the lawyers on
strong.
nted Claus von Billow, the Brit-
f the murder of his wife, Sunny.
mpson's team when the former
murders of his ex-wife, Nicole
!.nd Ronald Lyle Goldman. And
had been, neither one had had
villing and able to deploy in his
:imate friends with his lawyer.
:d, none of that mattered. Even if
molested were eighteen years
m— it didn't matter under Flor-
that in Epstein's case exceptions
even more concerned with each
the state attorney's office.
D asked the state attorney's office
ffrey Epstein.
/ took the extraordinary step of
all but demanding that he recuse
170
F 1 L
CHAPTER 45
Videotaped Deposition of Michael Reiter in B.B. vs.
Epstein, a civil lawsuit against Jeffrey Epstein:
November 23, 2009
Q: At some point you sent a letter to state attorney Barry
Krischer. Let me show you what we'll mark as exhibit 3. Let
me give you a chance to read through this letter again to help
refresh your recollection.
A: I've read it.
Q: At this point, in May of 2006, I'm assuming based on what
you told us before that you had had some conversations with
Barry Krischer directly. ...by phone—correct? —prior to this
letter.
A: I had conversations in person and by phone.
Q: Okay. But nonetheless in May—May 1, 2006—you felt the
need to write this letter; is that correct?
A: Yes.
172
Q: Can you tell us why?
A: Well, I felt the handling-..
way the state attorney's ofi
unusual. I knew that M
about this case. I felt tha
felt that the appropriate
governed the assignment
that his action met the st
from the statute in here. .A
wouldn't return my phone
The detective attempt
state attorney's office, Lai
nounce that ... and she \Ai(
the letter in hope that he m
realize that his objectivit)
case and ask the governor
like that was necessary fen
had been submitted to hin
Could you tell us, explain
tivity may be lacking in r
other words, what eviden(
you felt made it potentially
A: Well ... when I first told h
that it was a serious case, I
[and] that the suspect was
it. And we were—it was i
meeting that he and I w(
known him to be a victim
of children. Well, I know tl
statute that addresses tho
Q:
FILTHY RICH
Q:
A:
Q:
Can you tell us why?
Well, I felt the handling—and just continued to feel that the
way the state attorney's office handled this case was extremely
unusual. I knew that Mr. Krischer was making decisions
about this case. I felt that his objectivity was lacking, and I
felt that the appropriate way, after reading the statute that
governed the assignment of cases to other circuits—I felt
that his action met the standard. I used some of the words
from the statute in here. And I attempted to call him, and he
wouldn't return my phone calls.
The detective attempted to contact—his contact in the
state attorney's office, Lanna Belohlavek, however you pro-
nounce that ... and she wouldn't return his calls. So I wrote
the letter in hope that he would think about his situation and
realize that his objectivity was insufficient to prosecute the
case and ask the governor to appoint someone else. And I felt
like that was necessary for a fair prosecution of our case that
had been submitted to him.
Could you tell us, explain to us, why you felt that his objec-
tivity may be lacking in regards to this prosecution ... ? In
other words, what evidence did you see here, uncover, that
you felt made it potentially nonobjective?
A: Well ... when I first told him about the case, and I realized
that it was a serious case, [that] there were multiple victims,
[and] that the suspect was very well known, I told him about
it. And we were—it was in person. I talked to him after a
meeting that he and I were both involved in. And I had
known him to be a victim advocate and to protect the rights
of children. Well, I know that he even wrote a portion of the
statute that addresses those issues. And when I told him
173
CHAPTER 45
Michael Reiter in B.B. vs.
ainst Jeffrey Epstein:
a letter to state attorney Barry
a what we'll mark as exhibit 3. Let
ad through this letter again to help
1006, I'm assuming based on what
u had had some conversations with
by phone —correct? —prior to this
rson and by phone.
i May—May 1, 2006—y0u felt the
is that correct?
172
JAMES PATTERSON
originally, he said, "Let's go for it; this is an adult male in his
fifties who's had sexual contact with children of the ages of
the victims." He said this is somebody who we have to stop.
And whatever we need, he said, in the state attorney's office,
we have a unit that's equipped to investigate and prosecute
these kinds of cases. And I didn't have too many facts early
on when I talked with him, but I knew that there were multi-.
pie victims and to our detectives they were believable. So
when time went on and Mr. Epstein became aware of the
investigation and his lawyers contacted the state attorney's
office, they told me that.
And from that point on, and I believe it was Mr. Dershow-
itz initially, the tone and tenor of the discussions of this case
with Mr. Krischer changed completely. [At] one point he sug-
gested that we write [Epstein] a notice to appear, which
would be for a misdemeanor. He just completely changed
from not only our first conversation about this( —when] he
didn't know the name Jeffrey Epstein— till when he had
been informed on Mr. Epstein's reputation and his wealth,
and I just thought that very unusual.
I feel like I know him or knew him very well, the state
attorney, and I just felt like he could not objectively make
decisions about this case: that is why I wrote it.
174
Detective Recarey: May
Chief Reiter's letter to ti
effect.
Krischer did not
arrest warrant was issued. At
tive Recarey received a telep
ney Daliah Weiss, who advis
the Epstein case.
Weiss had been the perfe.
member of the special victir
and crimes against children, p
ing rape, aggravated child al
added another lawyer, a man
Goldberger his attorney of rei
. Goldberger was friendly A
ciate of Goldberger's was mar
TTERSON
...or it; this is an adult male in his
:act with children of the ages of
somebody who we have to stop.
aid, in the state attorney's office,
)ed to investigate and prosecute
didn't have too many facts early
Nit I knew that there were multi-
..ctives they were believable. So
r. Epstein became aware of the
Ts contacted the state attorney's
and I believe it was Mr. Dershow-
ior of the discussions of this case
mpletely. [At] one point he sug-
tein] a notice to appear, which
ior. He just completely changed
versation about this] —when] he
Frey Epstein— till when he had
tein's reputation and his wealth,
• unusual.
or knew him very well, the state
:e he could not objectively make
hat is why I wrote it.
174

[admin]

CHAPTER 46
Detective Recarey: May 2006
Chief Reiter's letter to the state attorney had no perceptible
effect.
Krischer did not recuse himself from the case. No
arrest warrant was issued. And on the afternoon of May 3, Detec-
tive Recarey received a telephone call from assistant state attor-
.ney Daliah Weiss, who advised him that she had been taken off
the Epstein case.
Weiss had been the perfect person to prosecute Epstein. As a
member of the special victims unit, she focused on sex crimes
and crimes against children, prosecuting high-profile cases involv-
ing rape, aggravated child abuse, and neglect. But Epstein had
added another lawyer, a man named Jack Goldberger, and made
Goldberger his attorney of record.
Goldberger was friendly with Barry Krischer— and an asso-
ciate of Goldberger's was married to Daliah Weiss.
175
JAMES PATTERSON
FILTI
If Epstein's legal team had wanted to remove Weiss from the
case, this would have been a good way to do it.
Nine days later, Detective Recarey met with ASA Lanna
Belohlavek, who told him that her boss, Barry Krischer, had asked
her again to take the case to the grand jury. Recarey told Belohlavek
that he had already requested arrest warrants for Epstein, Sarah Kel-
len, and Wendy Dobbs. The Palm Beach PD had finished its investi-
gation months earlier, he said, and had been waiting since then for
the case to move forward. He asked her once more to issue the war-
rants. Once again Belohlavek declined, saying that the original offer
her office had made to Epstein's old lawyer had been resubmitted to
the new lawyer. When Epstein's reply came, she would call.
While waiting for that call, Recarey received several calls
from Mary's father, who told him that he was being followed by a
green Chevrolet Monte Carlo— tailed so aggressively that other
vehicles were being run off the road. Recarey ran the plates and
found that the Chevy was registered to one Zachary Bechard of
Jupiter, Florida.
Bechard was a licensed private eye.
"A funny thing happened in Palm Beach," says Tim Malloy, who
was working as a TV newscaster in South Florida at the time.
"This would have been right around the time that Michael
Reiter sent his letter asking Barry Krischer to recuse himself
from the case. I didn't even know what Epstein looked like,
really, at the time. We had pictures taken by the British tabloids,
where the link to Prince Andrew first broke. But we didn't have
too many of them. What we did have was a contact in the hangar
where Epstein kept his 727.
176
"I don't know how much y
national Airport. It's the kind
valet parking, and waiting loin
you'll see in Manhattan. It's
Saudi princes, heads of state. I'
vacy. You can bring limousine:
out Epstein was very secretive
want anyone to know the tail n
"But our contact didn't like
how young the girls around EF
had the 727's tail number, an
someone I won't say too mucl
flight plan for a certain trip hi
going to land at the airport. A]
the station's traffic helicopter a
hundred feet a quarter mile sou
"Our cameraman had a tele
tight shot, on video, of Epstein
did get the shot: Epstein, with
flipped up over his neck, about
that was waiting for him.
"Then he saw our helicopter
"I was doing a live voice-ov(
first video anyone had on him I
run back onto the plane. The:
break, my producer told me
Epstein wants us to stop taking
talk to you.'
"The cameraman kept rolli:
out, got into a car with tinted w-
TTERSON
FILTHY RICH
inted to remove Weiss from the
d way to do it.
Recarey met with ASA Lanna
r boss, Barry Krischer, had asked
sand jury. Recarey told Belohlavek
st warrants for Epstein, Sarah Kel-
Beach PD had finished its investi-
d had been waiting since then for
td her once more to issue the war-
ined, saying that the original offer
Id lawyer had been resubmitted to
tply came, she would call.
, Recarey received several calls
n that he was being followed by a
- tailed so aggressively that other
road. Recarey ran the plates and
tered to one Zachary Bechard of
ate eye.
lm Beach," says Tim Malloy, who
:r in South Florida at the time.
ht around the time that Michael
;arry Krischer to recuse himself
know what Epstein looked like,
tires taken by the British tabloids,
first broke. But we didn't have
have was a contact in the hangar
176
"I don't know how much you know about Palm Beach Inter-
national Airport. It's the kind of place that has private hangars,
valet parking, and waiting lounges that look as chic as anything
you'll see in Manhattan. It's an airport for the rich, basically.
Saudi princes, heads of state. Powerful men who value their pri-
vacy. You can bring limousines onto the tarmac. And we found
out Epstein was very secretive about his dealings there. He didn't
want anyone to know the tail numbers on his planes.
"But our contact didn't like Epstein. And he was horrified by
how young the girls around Epstein were. So thanks to him, we
had the 727's tail number, and thanks to one other source—
someone I won't say too much about here—we had Epstein's
flight plan for a certain trip he was making. We knew he was
going to land at the airport. And so our producer climbed into
the station's traffic helicopter and told the pilot to hover at five
hundred feet a quarter mile south of the field.
"Our cameraman had a telephoto lens. The idea was to get a
tight shot, on video, of Epstein deplaning. And for a moment we
did get the shot: Epstein, with the collar of his cashmere coat
flipped up over his neck, about to run down the steps into a cart
that was waiting for him.
"Then he saw our helicopter, with the station's markings.
"I was doing a live voice-over on Epstein's arrival. It was the
first video anyone had on him up to that point. But Epstein had
run back onto the plane. Then, during the next commercial
break, my producer told me through my headpiece: 'Jeffrey
Epstein wants us to stop taking his picture. In fact, he wants to
talk to you.'
"The cameraman kept rolling. And eventually Epstein got
_out, got into a car with tinted windows, and was driven over the
177
JAMES PATTERSON
bridge to his home in Palm Beach. So in a sense we failed to get
the story. But the fact that Epstein would call a news program
from his plane and command them to order the program's traffic
helicopter away—that says something about the man's arro-
gance. And maybe his temper."
Mary: July 2006
0 n June 29, assistant s
Detective Recarey th;
would be going to a
convened for July 19.
On July 12, Recarey spok
that she still hadn't heard fr
too, was odd, since Recarey
upon to testify.
She was back in Palm Be2
out-of-state relatives.
All in all, it had been a ve
"What has happened to
father would say.
Mary had been sent to
her it was the wrong place at
.•
178
rTERSON
h. So in a sense we failed to get
em n would call a news program
nn to order the program's traffic
:nething about the man's arro-
CHAPTER 47
Mary: July 2006
0 n June 29, assistant state attorney Lanna Belohlavek told
Detective Recarey that despite his protestations, the case
would be going to a grand jury after all. One had been
convened for July 19.
On July 12, Recarey spoke with Mary's stepmother, who said
that she still hadn't heard from the state attorney's office. This,
too, was odd, since Recarey knew that Mary would be called
upon to testify.
She was back in Palm Beach now, after months of living with
out-of-state relatives.
All in all, it had been a very tough year for Mary.
"What has happened to my daughter's life is criminal," her
father would say.
Mary had been sent to a school for troubled children. For
her it was the wrong place at the worst time in her life. She had
179
178
JAMES PATTERSON
gotten into more fights there, growing depressed and withdrawn
from her sister and parents. Helplessly, her parents watched her
spiral out of control. As they neared the end of their rope, they
sent her out of state. But after the move, Mary had fallen apart
completely. She used drugs, fell in with a bad crowd, ran away
from her relatives, and shacked up with a gang of drug dealers.
When the gang was busted by local police, the dealers blamed
Mary for snitching and put out the word that they wanted her
dead.
"We had to move her again," Mary's father explained. "We
finally got her into therapy—she's still seeing the therapist. And
worst of all, she developed HPV. She's already had to have a seri-
ous operation."
Mary's troubles didn't end there. On June 28, she was brought
in front of the grand jury. She hadn't been briefed by the state
attorney—she hadn't even met the prosecutors—and she had
no idea what she would be asked.
Almost immediately, she found that she was being treated
more like a criminal than like a witness or victim.
"The prosecutor produced a printout of our daughter's
Myspace page," Mary's father recalls. "Mary was stunned. She
began to cry. The prosecutor accused her of all sort of things; it
was like she was working for Epstein.
"All this time, we knew that we were being watched. Creepy
guys. Private investigators from Miami. They would follow us,
scaring the hell out of my wife and Mary's sister. My car was van-
dalized. It was like living in hell."
By this point, Epstein's defense dream team included Jack
Goldberger, Alan Dershowitz, and Gerald Lefcourt. All of them
had excellent track records. Dershowitz and Lefcourt were two
180
of America's most famous
celebrity lawyer—Ken Sta
had had Bill Clinton impeac
team.
As far as Mary's parents
walked into an ambush. EVE
playing defense on the side
ond girl—Alison, who cla:
never testified in court at al
TERSON
FILTHY RICH
wing depressed and withdrawn
,lessly, her parents watched her
tred the end of their rope, they
le move, Mary had fallen apart
in with a bad crowd, ran away
ip with a gang of drug dealers.
rlocal police, the dealers blamed
the word that they wanted her
," Mary's father explained. "We
e's still seeing the therapist. And
She's already had to have a seri-
.ere. On June 28, she was brought
hadn't been briefed by the state
: the prosecutors—and she had
d.
mud that she was being treated
t witness or victim.
a printout of our daughter's
recalls. "Mary was stunned. She
ccused her of all sort of things; it
)stein.
it we were being watched. Creepy
m Miami. They would follow us,
and Mary's sister. My car was van-
:11."
Jense dream team included Jack
and Gerald Lefcourt. All of them
)ershowitz and Lefcourt were tWO.
180
of America's most famous lawyers, and before long, another
celebrity lawyer —Ken Starr, the former solicitor general who
had had Bill Clinton impeached for perjury—would join Epstein's
team.
As far as Mary's parents were concerned, their daughter had
walked into an ambush. Everyone in the courtroom seemed to be
playing defense on the side of Jeffrey Epstein. And as for the sec-
ond girl—Alison, who claimed that she had been raped—she
never testified in court at all.
181
CHAPTER 48
Michael Reiter: July 2006
0 n July 28, the grand jury reached a verdict that floored
the Palm Beach PD.
The original plea deal that Krischer had offered to
Epstein had been bad enough. Now the grand jury was recom-
mending that Epstein be charged with just one felony count of
solicitation of prostitution.
There was no mention of underage girls. The original
accusation— four felony counts of unlawful sex acts with minors
and one felony count of lewd and lascivious molestation—had
simply evaporated.
It wasn't enough to send Epstein to prison.
Epstein was allowed to surrender on a Sunday, when no one
would know he'd been arraigned. A few hours later, he was
released on three thousand dollars bail.
The Palm Beach PD was not even notified.
182
Once again, Chief Reite
took the extraordinary stej
prosecutor's office.
At the time, the federal
Florida was a Republican
Reiter recalls being presen
and remembers Acosta's de(
be the prosecution, to the
who takes advantage of th
sex crimes. Disgusted with
recalls thinking he'd found 1
In Acosta, the chief saw
from confronting a man vc
connections.
But it turned out that Ac
Starr's high-powered multir
And while Acosta had a stei
clerking for future Supreme
only argued two cases befor(
At the time, Reiter did not
one had to look much more se
Reiter's actions did not nece
not in every corner of the coi
"I had individuals sugge1
the investigation and my ref
was more horsepower than
had other individuals suggc
probably fits," Reiter said in 1
FILTHY RICH
CHAPTER 48
ry reached a verdict that floored
Leal that Krischer had offered to
Now the grand jury was recom-
ged with just one felony count of
pf underage girls. The original
s of unlawful sex acts with minors
and lascivious molestation—had
)stein to prison.
-render on a Sunday, when no one
gned. A few hours later, he was
llars bail.
)t even notified.
182
Once again, Chief Reiter was outraged. So much so that he
took the extraordinary step of calling the FBI and the federal
prosecutor's office.
At the time, the federal prosecutor of the Southern District of
Florida was a Republican named R. Alexander Acosta. Chief
Reiter recalls being present at Acosta's swearing-in ceremony
and remembers Acosta's declaration that one of his goals would
be the prosecution, to the fullest extent of the law, of anyone
who takes advantage of the weak—especially perpetrators of
sex crimes. Disgusted with Krischer's laissez-faire attitude, Reiter
recalls thinking he'd found his man.
In Acosta, the chief saw a prosecutor who wouldn't shy away
from confronting a man with Jeffrey Epstein's resources and
connections.
But it turned out that Acosta had worked under Ken Starr at
Starr's high-powered multinational law firm, Kirkland & Ellis.
And while Acosta had a sterling resume, which included a stint
clerking for future Supreme Court justice Samuel Alito, he had
only argued two cases before a judge.
At the time, Reiter did not know this. All he knew was that some-
one had to look much more seriously into Jeffrey Epstein's crimes.
Reiter's actions did not necessarily make him a hero—at least,
not in every corner of the community he served.
"I had individuals suggest that the department's approach to
the investigation and my referral of the investigation to the FBI
was more horsepower than the investigation deserved. And I
had other individuals suggest that—yeah, the term 'back off'
Probably fits," Reiter said in his deposition for B.B. vs. Epstein.
183
JAMES PATTERSON
"My responsibility was to
Beach and preserve their con:
department for all," Reiter sai
particularly under the crimin
the nature of our system, be ti
But along with handing t
attorney, Reiter took another
letters—on Palm Beach PD I
victims in the case.
He delivered the letters by
"I had people in the community in Palm Beach who either made
comments directly to me or to others who relayed them to me that I
didn't need to take the tack in the investigation that we did, which is
[to] completely investigate it and then refer it to • the FBI after the
state case was resolved," Reiter said in the deposition. "I had one
individual who came to see me a couple of times about this."
According to the chief, the individual in question was a
prominent Palm Beach politician.
"He said this wasn't necessary; this was a case that was really
very minor," Reiter recalled. "The victims had lifestyles that
don't make them—shouldn't make them believable to the police
department."
"I told him that those kinds of suggestions to me were
improper and he should stop," said Reiter. "That he had taken a
couple of steps down the road toward something that could
eventually constitute a crime. We talked several times. Early on
it didn't end favorably. You know, this is an individual [whom] I
had to interact with in my official capacity and in his official
capacity as well."
The Palm Beach politician wasn't the only one to pressure
the police chief. "I received comments from a variety of different
viewpoints ... in some cases I had people tell me, hey, he's a Palm
Beacher, why are you investigating a Palm Beacher?" Reiter
would say when deposed. "I had people that said it was an unfa-
vorable career move for me to ask the state attorney to remove
himself from the case and to refer it to the FBI.... I had plenty of
people that told me that that was a mistake."
Reiter didn't back off. To have done so would have been a
betrayal—not only of the victims but also of his vocation and
the community he had sworn he would serve.
184
TTERSON
FILTHY RICH
y in Palm Beach who either made
ers who relayed them to me that I
nvestigation that we did, which is
then refer it to. the FBI after the
aid in the deposition. "I had one
uple of times about this."
: individual in question was a
1.
y; this was a case that was really
The victims had lifestyles that
ike them believable to the police
ids of suggestions to me were
;aid Reiter. "That he had taken a
I toward something that could
Ve talked several times. Early on
Ar, this is an individual [whom] I
icial capacity and in his official
wasn't the only one to pressure
iments from a variety of different
id people tell me, hey, he's a Palm
gating a Palm Beacher?" Reiter
d people that said it was an unfa-
ask the state attorney to remove
fer it to the FBI.... I had plenty of
is a mistake."
lave done so would have been a
ims but also of his vocation and
te would serve.
184
"My responsibility was to protect everyone that lives in Palm
Beach and preserve their constitutional rights and be the police
department for all," Reiter said. "And I think that under the law,
particularly under the criminal laws, that all people have to, by
the nature of our system, be treated exactly alike."
But along with handing the case off to the FBI and the US
attorney, Reiter took another unusual step. He wrote personal
letters—on Palm Beach PD letterhead— to the parents of the
victims in the case.
He delivered the letters by hand.
185
TOWN OF PALM BEACH
POLICE DEPARTMENT
A NixitcNixt. AND STA1E ACCMITED LAW NPORCEMENT AC:ENCV kPOLICE.li
July 24. 2006
HAND DELIVERED
BMA,
Dear mripm
Your claughterlanwas the victim of a crime which nas been investigated by the Palm
Beach Police Department and subsequently referred for prosecution to the Pdtm Beach
County State Attorneys Office. You may be aware that Jeffrey Epstein was indicted on
charges of solicitation for orovitution by a Stele of Florida grand ply last week and turned
himself in at the Palm Beach County jail on Ju!iy 23. 2006.. Wntle I do not speak for them,
it is my understanding that is the full context in which the Palm Beach County State
Attorney's Office intends to address the chrges that invowed tne crime in which your
daughter was victim.
Please know tnat it is the role and responsibility of law enforcement to investigate Crime
and to refer ap3ropriate charges to the prosecutor for consideration. I believe that the
Palm Beach Police Department has acted competently and responsibly in carrying out Ins
le. Should you haverany questions concemlng the state prosecution of this matter, they
are best addressed by the Palm Beach Count State Attorneys Office
do not feel that Justice has been sufficiently served by the indictment that has been
issued. Therefore, please Imo?. that his matter has been referreo to the Federal Bureau
e Investigation to determine if violations of federal law have occurred. In the ehent that
the FBI should choose to pursue this matter, tne Palm Beach Police Department will assist
tnern in their investigation Of potential violations of federal law.
Please feel free to contact rne at (561) 838-5460 should you have any questions
Sincerely,
1W40.J.0 as2,1t,
r.richael S Reitr
Chief of Police
14SR.nt
I4S S., Co.... PoE• • Poll, Reset Fen as 3'AP0-403 • r$ii) fta sit": • F.:z 1,75..*: • • —• • ••••••,..
Jeffrey Epstein: Septemi
In the winter of 2013, Scc
die school principal from
be sentenced to the m
years in prison, with ten ye
ing guilty to one charge of sc
Blake's crime? He sent SE
ton Beach police officer who N
boy. But in a sense, Blake v
tenced to life. The case was a
treatment regular Florida fol.]
with a minor. But nothing a
and the plea deal he mana
extraordinary.
Epstein had bought himse
assembled. His connections
LM BEACH
ARTMPNT
LAW ENIFORCVENT ArZENCY
4.2006
which has been investigated by the Palm
tarred for prosect:tion to the Palm Beach
.vare that Jeffrey Epstein was indicted on
of Florida grand jury last week and turned
23. 2006. While I do not speak tor them,
in which the Palm Beach County State
es that invoNed tne crime in which your
"Of law enforcement to investigate crime
Jlor for consideration. I beleve that the
etentiy and responsibly in carrying out this
the state prosecution of this matter, they
State Attame/5 Office
served by the Indictment that has been
has been referred to the Federal Bureau
era i law have occurred. In the event that
Palm Beach Police Deoartmeit will assist
of federal law.
0 should you have any questons
sly,
S Reiter
4 Patice
s3.5,g.• pa, !w;1;5.erre•
CHAPTER 49
Jeffrey Epstein: September 2007
1 n the winter of 2013, Scott Blake, a forty-seven-year-old mid-
dle school principal from Palm Beach Gardens, Florida, would
be sentenced to the minimum mandatory sentence— ten
years in prison, with ten years of probation on top—for plead-
ing guilty to one charge of soliciting sex with a minor.
Blake's crime? He sent sexually charged messages to a Boyn-
ton Beach police officer who was pretending to be a fifteen-year-old
boy. But in a sense, Blake was lucky: he could have been sen-
tenced to life. The case was an interesting example of the kind of
treatment regular Florida folks could expect just for soliciting sex
with a minor. But nothing about Jeffrey Epstein was regular--
-
and the plea deal he managed to strike in 2007 was simply
extraordinary.
Epstein had bought himself one of the best defense teams ever
assembled. His connections and contributions to Democratic
187
JAMES PATTERSON
FILT
causes had made him a player on that side of the political aisle. He
had a famous Republican, Bill Clinton's nemesis, Ken Starr, work-
ing the other side. And just to make sure they'd covered the bases,
Epstein's team also recruited Roy Black— the lawyer who'd
cleared William Kennedy Smith of rape and kept Rush Limbaugh
out of prison for his alleged illegal drug use—and Jay Lefkowitz,
a defense attorney who'd worked with US attorney R. Alexander
Acosta at Ken Starr's law firm.
And so in September, the US attorney's office reached a for-
mal agreement with Epstein's team: the United States would
defer federal prosecution in favor of prosecution by the state of
Florida.
A non-prosecution agreement (NPA) was drafted; among
other things, it assured Epstein that he would not be prosecuted
in the Southern District of Florida for felony offenses involving
the sexual abuse of underage girls. (By that point, thirty known
victims had been discovered.) Instead it allowed him to plead
guilty to state felony offenses for solicitation of prostitution and
the procurement of minors for prostitution. The NPA established
a procedure that allowed Epstein's victims to sue him in civil
court and took the extraordinary step of ensuring that "any
potential co-conspirators" of Epstein's would be immune from
prosecution.
"In consideration of Epstein's agreement to plead guilty and
to provide compensation in the manner described above, if
Epstein successfully fulfills all of the terms and conditions of
this agreement, the United States also agrees that it will not
institute any criminal charges against any potential co-conspira-
tors of Epstein," the agreement stated, mentioning Sarah Kellen
and Nadia Marcinkova by name.
188
"The parties anticipate tha
part of any public record," I
United States receives a Freed
any compulsory process comm
ment, it will provide notice
disclosure."
Remarkably, despite assur
feds, none of the victims was (
this NPA.
If Epstein did not sign the
count indictment and a decade
team of lawyers had gotten him
ted all the teeth in South Florid;
For all his protestations of it
in the world to agree to an NPA.
On September 24, 2007, Eps.
Once again, none of the I
notified.
189
'TERSON
FILTHY RICH
that side of the political aisle. He
nton's nemesis, Ken Starr, work-
ke sure they'd covered the bases,
Zoy Black—the lawyer who'd
)f rape and kept Rush Limbaugh
LI drug use—and Jay Lefkowitz,
. with US attorney R. Alexander
3 attorney's office reached a for-
team: the United States would
n. of prosecution by the state of
nt (NPA) was drafted; among
that he would not be prosecuted
ida for felony offenses involving
rls. (By that point, thirty known
Instead it allowed him to plead
)r solicitation of prostitution and
)rostitution. The NPA established
em's victims to sue him in civil
lary step of ensuring that "any
pstein's would be immune from
ri's agreement to plead guilty and
the manner described above, if
1 of the terms and conditions of
lates also agrees that it will not
against any potential co-conspira-
t stated, mentioning Sarah Kellen
Le.
188
"The parties anticipate that this agreement will not be made
part of any public record," the document concludes. "If the
United States receives a Freedom of Information Act request or
any compulsory process commanding the disclosure of the agree-
ment, it will provide notice to Epstein before making that
disclosure."
Remarkably, despite assurances they'd received from the
feds, none of the victims was consulted prior to the drafting of
this NPA.
If Epstein did not sign the agreement, he faced a fifty-seven-
count indictment and a decade or more in prison. But Epstein's
team of lawyers had gotten him a deal so sweet it could have rot-
ted all the teeth in South Florida.
For all his protestations of innocence, there was every reason
in the world to agree to an NPA.
On September 24, 2007, Epstein did sign it.
Once again, none of the victims had been consulted or
notified.
189
1
CHAPTER SO
Jane Doe: February 2008
As a result of the non-prosecution agreement, a fifty-three-
count indictment that federal prosecutors had prepared
against Jeffrey Epstein—one that claimed he'd abused
dozens of underage women—never was filed.
But as far as lawyers representing Epstein's victims were con-
cerned, the fact that those victims were not consulted about the
non-prosecution agreement was inexcusable. The "government
deliberately kept crime victims 'in the dark' so that it could enter
into a plea arrangement designed to prevent the victims from
raising any objections," they would argue, in documents filed on
February 10, 2016. For nine months, the lawyers claimed, from
the time that the NPA was signed, on September 24, 2007,
Krischer's office, "doing Epstein's bidding, [had] concealed the
NPA's existence from victim[s]" and continued to do so until the
190
moment that Epstein had
finally did June 30, 2008.
In the interim, accordi
were only told, "This case i
A lawsuit that Bradley I
Fort Lauderdale, filed in ji
Rights Act, or CVRA (tith
which states that "victims
ing the right to be heard ii
be precluded from court pr
fairly."
According to him, pros(
of the victims. Edwards, N
knew that this suit against
monetary recovery of any
also knew that if the goveri
entered into a contract thal
rights of Epstein's victims,
have been improper in an(
remedy would have been tc
while it is difficult to knoiA
contract is overturned, on€
could prosecute Epstein fo
statute of limitations on tho
At the time of this wr:
through the courts. It has
Bleak House— the Charles
is so massive and so compl€
everyone involved into the n
FILTHY RICH
CHAPTER 50
;ecution agreement, a fifty-three-
N:leral prosecutors had prepared
— one that claimed he'd abused
Lever was filed.
:nting Epstein's victims were con-
ims were not consulted about the
Is inexcusable. The "government
'in the dark' so that it could enter
ned to prevent the victims from
ould argue, in documents filed on
,onths, the lawyers claimed, from
signed, on September 24, 2007,
In's bidding, [had] concealed the
"and continued to do so until the
190
moment that Epstein had to plead guilty in court, which he
finally did June 30, 2008.
In the interim, according to their lawyers, Epstein's victims
were only told, "This case is currently under investigation."
A lawsuit that Bradley Edwards, a victims' rights attorney in
Fort Lauderdale, filed in July of 2008 cited the Crime Victims'
Rights Act, or CVRA (title 18, section 3771, of the US Code),
which states that "victims of federal crimes have rights, includ-
ing the right to be heard in court, and most particularly, not to
be precluded from court proceedings, and the right to be treated
fairly."
According to him, prosecutors had violated the CVRA rights
of the victims. Edwards, who said he was working pro bono,
knew that this suit against the government would not allow for
monetary recovery of any sort (including lawyers' fees). But he
also knew that if the government, urged by Jeffrey Epstein, had
entered into a contract that improperly or illegally violated the
rights of Epstein's victims, then that contract, by nature, would
have been improper in and of itself—in which case, the only
remedy would have been to have the contract invalidated. And
while it is difficult to know what, exactly, would happen if the
contract is overturned, one possibility is that the government
could prosecute Epstein for crimes against his victims, if the
statute of limitations on those crimes has not expired.
At the time of this writing, that case is winding its way
through the courts. It has all the earmarks of a modern-day
Bleak House........ the Charles Dickens novel about a legal case that
is so massive and so complex that it drags on forever and drags
everyone involved into the mire.
191
JAMES PATTERSON
* * *
In the meantime, Epstein began to settle out of court with his
victims.
In February of 2008, a Virginia woman who went by the alias
Jane Doe #2 brought a fifty-million-dollar lawsuit against Epstein.
At the time of their meeting, she claimed, Epstein was fifty-two
years old. She was a teenager, and her complaint, which was
made public, gave the rest of the world an early glimpse of what
Epstein, and the inner workings of his secret world, looked like
from a victim's perspective.
"Epstein is a financier and money manager with a secret cli-
entele limited exclusively to billionaires," the lawsuit alleged.
"He is himself a man of tremendous wealth, power and influ-
ence. He maintains his principal home in New York and also
owns residences in New Mexico, St. Thomas and Palm Beach,
FL. The allegations herein concern Epstein's conduct while at his
lavish estate in Palm Beach." The complaint continued:
Upon information and belief, Epstein has a sexual preference
and obsession for underage minor girls. He engaged in a plan
and scheme in which he gained access to primarily economi-
cally disadvantaged minor girls in his home, sexually
assaulted these girls, and then gave them money. In or about
2004-2005, Jane Doe, then approximately 16 years old, fell
into Epstein's trap and became one of his victims.
Upon information and belief, Jeffrey Epstein carried out
his schemes and assaulted girls in Florida, New York, and on
his private Island, known as Little St. James, in St. Thomas.
Epstein's scheme involved the use of young girls to recruit
192
underage girls. (Upon inj
who brought Jane Doe to
of Epstein, and will ther
plaint.) Under Epstein's r
ostensibly to give a weal
compensation in his Pal
would be contacted when
Palm Beach residence or
Epstein or someone on hi.
to bring one or more um
recruiter, upon informatic
economically disadvantag
Palm Beach County who
being offered— generally
session—and who were p
to authorities or have cre
conduct were made. Thi
Epstein's plan.
Epstein's plan reflected
Upon arrival at Epstein's
would be introduced to Sar
gathered the girl's persona
and telephone number. Ms
up a flight of stairs to a b(
table in addition to other
graphs of nude women lin
bedroom. The girl would ti
with Epstein, who would b,
then remove his towel and
and direct the girl to remol
FILTHY RICH
TER SON
to settle out of court with his
a woman who went by the alias
1-dollar lawsuit against Epstein.
Le claimed, Epstein was fifty-two
ind her complaint, which was
world an early glimpse of what
of his secret world, looked like
Loney manager with a secret cli-
llionaires," the lawsuit alleged.
lclous wealth, power and influ-
al home in New York and also
o, St. Thomas and Palm Beach,
:rn Epstein's conduct while at his
e complaint continued:
Epstein has a sexual preference
inor girls. He engaged in a plan
:d access to primarily economi-
girls in his home, sexually
gave them money. In or about
tpproximately 16 years old, fell
one of his victims.
Jeffrey Epstein carried out
rls in Florida, New York, and on
Little St. James, in St. Thomas.
the use of young girls to recruit
192
underage girls. (Upon information and belief, the young girl
who brought Jane Doe to Epstein was herself a minor victim
of Epstein, and will therefore not be named in this Com-
plaint.) Under Epstein's plan, underage girls were recruited
ostensibly to give a wealthy man a massage for monetary
compensation in his Palm Beach mansion. The recruiter
would be contacted when Epstein was planning to be at his
Palm Beach residence or soon after he had arrived there.
Epstein or someone on his behalf would direct the recruiter
to bring one or more underage girls to the residence. The
recruiter, upon information and belief, generally sought out
economically disadvantaged underaged girls from western
Palm Beach County who would be enticed by the money
being offered—generally $200 to $300 per "massage"
session—and who were perceived as less likely to complain
to authorities or have credibility if allegations of improper
conduct were made. This was an important element of
Epstein's plan.
Epstein's plan reflected a particular pattern and method.
Upon arrival at Epstein's mansion, the underaged victim
would be introduced to Sarah Kellen, Epstein's assistant, who
gathered the girl's personal information, including her name
and telephone number. Ms. Kellen would then bring the girl
up a flight of stairs to a bedroom that contained a massage
table in addition to other furnishings. There were photo-
graphs of nude women lining the stairway hall and in the
bedroom. The girl would then find herself alone in the room
with Epstein, who would be wearing only a towel. He would
then remove his towel and lie naked on the massage table,
and direct the girl to remove her clothes. Epstein would then
193
JAMES PATTERSON
perform one or more lewd, lascivious and sexual acts,
including masturbation and touching the girl's vagina.
Consistent with the foregoing plan and scheme, Jane Doe
was recruited to give Epstein a massage for monetary com-
pensation. Jane was brought to Epstein's mansion in Palm
Beach. Once at the mansion, Jane was introduced to Sarah
Kellen, who led her up the flight of stairs to the room with the
massage table. In this room, Epstein told Jane to take off her
clothes and give him a massage. Jane kept her panties and
bra on and complied with Epstein's instructions. Epstein
wore only a towel around his waste [sic]. After a short period
of time, Epstein removed the towel and rolled over exposing
his penis. Epstein began to masturbate and he sexually
assaulted Jane.
• After Epstein had completed the assault, Jane was then
able to get dressed, leave the room and go back down the
stairs. Jane was paid $200 by Epstein. The young girl who
recruited Jane was paid $100 by Epstein for bringing Jane to
him.
As a result of this encounter with Epstein, Jane experi-
enced confusion, shame, humiliation and embarrassment, and
has suffered severe psychological and emotional injuries.
194
Jeffrey Epstein: June 30, 2
n June 30, 2008, more
Officer Pagan's investig;
age girls, Jeffrey Epsti
County jail.
A few days earlier, Epstein
New York Times. At the time, I.
(the line having long since blu
Saint Jeff's.
"I respect the legal process
by this."
He'd spent years fighting
then the federal government, in
would have seen him emerge
battle had aged him. Mellowed 1-
all but boasted to a journalist fr
1
TERSON
lascivious and sexual acts,
aching the girl's vagina.
rig plan and scheme, Jane Doe
massage for monetary com-
!o Epstein's mansion in Palm
fane was introduced to Sarah
t of stairs to the room with the
ostein told Jane to take off her
ge. Jane kept her panties and
pstein's instructions. Epstein
laste [sic]. After a short period
owel and rolled over exposing
masturbate and he sexually
ted the assault, Jane was then
room and go back down the
Epstein. The young girl who
by Epstein for bringing Jane to
'ter with Epstein, Jane experi-
iation and embarrassment, and
:al and emotional injuries.
194
CHAPTER SI
Jeffrey Epstein: June 30, 2008
0 n June 30, 2008, more than three years after the start of
Officer Pagan's investigation into his dealings with under-
age girls, Jeffrey Epstein reported to the Palm Beach
County jail.
A few days earlier, Epstein had taken a phone call from the
New York Times. At the time, he'd been working, or vacationing
(the line having long since blurred), at his compound on Little
Saint Jeff's.
"I respect the legal process," Epstein had said. "I will abide
by this."
He'd spent years fighting the charges—fighting the state,
then the federal government, in an effort to avoid a sentence that
would have seen him emerge from prison an old man. But the
battle had aged him. Mellowed him, even. Months earlier, he had
all but boasted to a journalist from New York magazine.
195
JAMES PATTERSON
"It's the Icarus story, someone who flies too close to the sun,"
that journalist said in reference to "the agony" of Epstein's legal
"ordeal."
"Did Icarus like massages?" Epstein responded.
But after Epstein's indictment, there were no more boasts.
For the most part, he kept silent in public and retreated into his
Eyes Wide Shut world. And when the New York Times did manage
to get him to speak on the record, he spoke like a chastened man.
Sitting on his patio down on Little St. James, Epstein likened
himself to the shipwrecked Gulliver after he washes ashore on
Lilliput.
"Gulliver's playfulness had unintended consequences," he said.
On the eve of his departure, he had a few more things to say:
"That is what happens with wealth. There are unexpected
burdens as well as benefits...."
"Your body can be confined, but not your mind...."
"I am not blameless...."
Outside of the agreement he'd signed with the prosecutor's
office, this was the closest Epstein had come to admitting his
guilt. But strange details were sprinkled throughout the story.
He had formed a "board of directors of friends" who would coun-
sel him on his behavior. And, seemingly for the first time, he'd
hired a full-time masseur—a man.
Readers of the New York Times might have wondered: Epstein
was going to jail for eighteen months. What need would he have
for a full-time masseur?
The story's last line hinted at the answer: in preparation for
incarceration, Epstein had set up an e-mail alert.
From then on, his automatic reply would read "On vacation."
196
TERSON
PART V
Incarceration
who flies too close to the sun,"
o "the agony" of Epstein's legal
pstein responded.
it, there were no more boasts.
in public and retreated into his
the New York Times did manage
, he spoke like a chastened man.
Little St. James, Epstein likened
liver after he washes ashore on
intended consequences," he said.
le had a few more things to say:
wealth. There are unexpected
but not your mind...."
signed with the prosecutor's
Lein had come to admitting his
sprinkled throughout the story.
rs of friends" who would coun-
eemingly for the first time, he'd
an.
es might have wondered: Epstein
mths. What need would he have
at the answer: in preparation for
p an e-mail alert.
reply would read "On vacation."
96
CHAPTER 52
Jeffrey Epstein: June 30, 2008
The Palm Beach County Main Detention Center is on the
west side of Lake Worth Lagoon, which separates West
Palm Beach from the island of Palm Beach. Epstein's
home on El Brillo Way is five miles to the east. Mary's high
school is several miles to the west.
It's fitting, somehow, that this jail—which is the jail Epstein
ends up in, after turning himself in to the local sheriff—lies in
between the two points.
The detention center's inmates, their families, and their law-
yers call it the Gun Club, a reference not only to the jail's address,
on Gun Club Road, but also to its population of hustlers, bur-
glars, drug dealers, rapists, and murderers. There's the occa-
sional hooker as well. And, from time to time, Haitian refugees
are lodged there.
There are three thousand inmates in all.
199
JAMES PATTERSON
Some wait a year before making their way to the courthouse,
their date with the public defender, and an appearance before
the judge. Some get out much sooner, if only they can make bail.
But there's no bail without money—or at least collateral—and,
of course, being without money is often what lands people in jail
in the first place.
Jeffrey Epstein could have posted bail for every single inmate
in the Gun Club.
But that's just one of the ways in which Epstein is unlike his
fellow inmates. He's an admitted pedophile now. Even a famous one.
And, famously, pedophiles tend to fare poorly in jail.
Luckily for Epstein, Ric Bradshaw, the sheriff in charge of
local jails, transfers Epstein to the infirmary, where he spends
exactly one night before being transferred seven miles up the
road to a much smaller, safer location: the Palm Beach County
Central Detention Center—or, as it's known, the Stockade.
"It's not somewhere we'd put a serial killer," Ric Bradshaw says.
Most of the residents here are addicts who take part in drug
education programs, prostitutes, petty criminals, and drunks.
It's a far safer place for Epstein to be, and, unlike other inmates
(except, of course, those being held in solitary), he'll end up with
his own cell, even his own wing, which he has to himself.
Epstein's allowed to pay for a security guard, who sits outside the
cell and keeps watch. And he's allowed any number of visitors.
For a convicted felon, it's an extraordinary benefits package.
But according to Sheriff Bradshaw, who also oversees the Stock-
ade, Epstein is incredulous over the treatment he is receiving.
"He was astonished that he had to go to prison at all," Brad-
shaw remembers.
"Let's just say he didn't think he belonged there."
200
*et
Sheriff Ric Bradshaw: June
0 ur job," says Ric Bradsl
killed him."
Sheriff Bradshaw co
Western. Imposingly tall, witt
mustache, and slow, southern
old-school law officer— the ki]
patrolling the streets of Tombst
He's been a lawman for forty-fi
been spent as the head of the co
talk to the media, and today, as
he's clearly uncomfortable, fidget
But here in his wood-panele
Gun Club, Bradshaw remembers
,' "We have a thousand sexua
says. When he arrived here, he
i
20
LTTERSON
:ing their way to the courthouse,
.nder, and an appearance before
)oner, if only they can make bail.
fey—or at least collateral—and,
is often what lands people in jail
)osted bail for every single inmate
ays in which Epstein is unlike his
pedophile now. Even a famous one.
tend to fare poorly in jail.
;radshaw, the sheriff in charge of
o the infirmary, where he spends
ig transferred seven miles up the
location: the Palm Beach County
r, as it's known, the Stockade.
a a serial killer," Ric Bradshaw says.
are addicts who take part in drug
ltes, petty criminals, and drunks.
in to be, and, unlike other inmates
g held in solitary), he'll end up with
1 wing, which he has to himself.
security guard, who sits outside the
allowed any number of visitors.
an extraordinary benefits package.
radshaw, who also oversees the Stock-
rer the treatment he is receiving.
he had to go to prison at all," Brad-
hink he belonged there."
200

[admin]

CHAPTER 53
Sheriff Ric Bradshaw: June 2015
ur job," says Ric Bradshaw, "was to make sure nobody
killed him."
Sheriff Bradshaw could have stepped off the set of a
Western. Imposingly tall, with his cowboy hat, Kurt Russell
mustache, and slow, southern drawl, he looks exactly like an
old-school law officer—the kind you once would have found
patrolling the streets of Tombstone, Deadwood, or Dodge City.
He's been a lawman for forty-four years, eleven of which have
been spent as the head of the county's jails. As a rule, he doesn't
talk to the media, and today, as he talks about Jeffrey Epstein,
he's clearly uncomfortable, fidgety, and ill disposed.
But here in his wood-paneled office on the first floor of the
Gun Club, Bradshaw remembers Epstein quite well.
"We have a thousand sexual predators in the county," he
says. "When he arrived here, he was one of them. He definitely
201
JAMES PATTERSON
FIJ
fit the category we have to ensure the general population is not
going to take their anger out on."
Although he understands that Epstein is a sex offender
and has a sense of the scope of his alleged crimes, Bradshaw's
also aware that the actual conviction was for a "low-level felony."
At the request of Epstein's attorneys—a request that is con-
firmed by a court order—Epstein is quickly granted "work
release."
What it means in practice is that six days a week, for up to
sixteen—sixteen! —hours each day, Epstein is allowed to leave
the Stockade to be driven by a designated driver in a car ear-
marked especially for him to any one of three places: his lawyer
Jack Goldberger's office in downtown West Palm Beach, the
Palm Beach office of a science foundation that he's established,
and his house on El Brillo Way.
Despite the ankle bracelet he wears, it could be argued that
as a fabulously rich prisoner with two of his own jets parked
nearby, at the Palm Beach International Airport, Epstein might
have posed a flight risk.
Instead, every day of the week save one, he's allowed to go to
his lawyer's, to go to his office, or simply to go home.
Did the deputy in charge of Epstein go to the house on El
Brillo Way?
Ric Bradshaw considers the question.
"Yes," he says, "he did."
Did the deputy go inside the house?
"Yes, he did."
If so, the deputy might have encountered Nadia Marcinkova,
who was staying on El Brillo Way at the time. He may also have
202
met a suave short-haired ge)
French accent.
That would be Jean-Luc
For the duration of Jeffre
the Stockade, Brunel's taken
Brillo Way.
2(
'ATTERSON
FILTHY RICH
Jure the general population is not
1.
that Epstein is a sex offender
of his alleged crimes, Bradshaw's
liction was for a "low-level felony."
ttorneys— a request that is con-
pstein is quickly granted "work
is that six days a week, for up to
ch day, Epstein is allowed to leave
• a designated driver in a car ear-
any one of three places: his lawyer
lowntown West Palm Beach, the
e foundation that he's established,
y.
t he wears, it could be argued that
with two of his own jets parked
.ternational Airport, Epstein might
week save one, he's allowed to go to
e, or simply to go home.
e of Epstein go to the house on El
he question.
the house?
ave encountered Nadia Marcinkova,
) Way at the time. He may also have
202
met a suave short-haired gentleman who spoke with a distinct
French accent.
That would be Jean-Luc Brunel.
For the duration of Jeffrey Epstein's stay—or half stay—in
the Stockade, Brunel's taken up residence in the house on El
Brill° Way.
203
F1
fraudster named Arnold Pr
had been commuted by Bill
left office.
Sheriff Bradshaw wants
conjugal.
But even US attorney Aca
agreement with the governm(
ment was highly irregular.
"Epstein appears to have
while in jail," Acosta would
eral public. "Although the tei
are a matter appropriately lei
eral authorities, without doi
while in state custody underrr
And, of course, Epstein's:
by taxpayers.
CHAPTER 54
Jeffrey Epstein: June 30, 2008—July 21, 2009
ccording to Sheriff Ric Bradshaw, the treatment Jeffrey
Epstein received in the Stockade was not preferential. By
some measures, he isn't wrong.
In 2010, millionaire polo mogul John Goodman killed a
young man while driving drunk. He was convicted but was
allowed to spend two years under house arrest while his appeal
was being tried.
Like Epstein, Goodman was allowed visitors. But Goodman's
visitor list was nothing like Jeffrey Epstein's.
Nadia Marcinkova is said to have visited Epstein in jail more
than seventy times.
Epstein's assistant Sarah Kellen also visited Epstein in the
Stockade.
A Russian mixed martial artist named Igor "Houdini" Zinoviev was another visitor, as was a disbarred lawyer and financial
204
FILTHY RICH
CHAPTER 54
!008-July 21, 2009
c Bradshaw, the treatment Jeffrey
Stockade was not preferential. By
't wrong.
o mogul John Goodman killed a
Irunk. He was convicted but was
inder house arrest while his appeal
vas allowed visitors. But Goodman's
effrey Epstein's.
I to have visited Epstein in jail more
Kellen also visited Epstein in the
ii artist named Igor "Houdini" Zino
-
was a disbarred lawyer and financial
204
fraudster named Arnold Prosperi, whose own prison sentence
had been commuted by Bill Clinton on the day before Clinton
left office.
Sheriff Bradshaw wants to be clear: none of these visits was
conjugal.
But even US attorney Acosta, who negotiated Epstein's unusual
agreement with the government, would say that Epstein's arrange-
ment was highly irregular.
"Epstein appears to have received highly unusual treatment
while in jail," Acosta would say in a letter addressed to the gen-
eral public. "Although the terms of confinement in a state prison
are a matter appropriately left to the state of Florida and not fed-
eral authorities, without doubt, the treatment that he received
while in state custody undermined the purpose of a jail sentence."
And, of course, Epstein's stay at the Stockade was subsidized
by taxpayers.
205
Fi
CHAPTER 55
R. Alexander Acosta's letter to the general public,
March 20, 2011
To whom it may concern:
I served as U. S. Attorney for the Southern District of Florida
from 2005 through 2009. Over the past weeks, I have read
much regarding Mr. Jeffrey Epstein. Some appears true,
some appears distorted. I thought it appropriate to provide
some background, with two caveats: (i) under Justice Depart-
ment guidelines, I cannot discuss privileged internal com-
munications among department attorneys and (ii) I no longer
have access to the original documents, and as the matter is
now nearly 4 years old, the precision of memory is reduced.
The Epstein matter was originally presented to the
Palm Beach County State Attorney. Palm Beach Police
alleged that Epstein unlawfully hired underage high
206
school females to provic
massages. Police sought
resulted in a term of im
reports, however, in 200(
to concerns regarding th(
to charge Epstein only
assault with no intent tc
would have resulted in
register as a sexual offet
underage victims.
Local police were di!
ney's conclusions, and res
Federal authorities recei
engaged in additional invt
the quality of the evidenc(
at trial. With a federal
considerations. First, a
requires that the crime be
an interstate nexus. Seco]
charged by the state, the fe
extent, to back-stop state
is no miscarriage of justice
erally that which has alre
level.
After considering the q
additional considerations,
the state charge was insufi
the prosecutors and age
Mr. Epstein's attorney, Rc:,
best known for his suc
CHAPTER 55
er to the general public,
T the Southern District of Florida
Dver the past weeks, I have read
ey Epstein. Some appears true,
thought it appropriate to provide
D caveats: (i) under Justice Depart-
discuss privileged internal com-
ment attorneys and (ii) I no longer
I. documents, and as the matter is
precision of memory is reduced.
was originally presented to the
te Attorney. Palm Beach Police
Ilawfully hired underage high
206
FILTHY RICH
school females to provide him sexually lewd and erotic
massages. Police sought felony charges that would have
resulted in a term of imprisonment. According to press
reports, however, in 2006 the State Attorney, in part due
to concerns regarding the quality of the evidence, agreed
to charge Epstein only with one count of aggravated
assault with no intent to commit a felony. That charge
would have resulted in no jail time, no requirement to
register as a sexual offender and no restitution for the
underage victims.
Local police were dissatisfied with the State Attor-
ney's conclusions, and requested a federal investigation.
Federal authorities received the State's evidence and
engaged in additional investigation. Prosecutors weighed
the quality of the evidence and the likelihood for success
at trial. With a federal case, there were two additional
considerations. First, a federal criminal prosecution
requires that the crime be more than local; it must have
an interstate nexus. Second, as the matter was initially
charged by the state, the federal responsibility is, to some
extent, to back-stop state authorities to ensure that there
is no miscarriage of justice, and not to also prosecute fed-
erally that which has already been charged at the state
level.
After considering the quality of the evidence and the
additional considerations, prosecutors concluded that
the state charge was insufficient. In early summer 2007,
the prosecutors and agents in this case met with
Mr. Epstein's attorney, Roy Black. Mr. Black is perhaps
best known for his successful defense of William
207
JAMES PATTERSON
Fij
Kennedy Smith. The prosecutors presented Epstein a
choice: plead to more serious state felony charges (that
would result in 2 years' imprisonment, registration as a
sexual offender, and restitution for the victims) or else
prepare for a federal felony trial.
What followed was a year-long assault on the prose-
cution and the prosecutors. I use the word assault inten-
tionally, as the defense in this case was more aggressive
than any which I, or the prosecutors in my office, had
previously encountered. Mr. Epstein hired an army of
legal superstars: Harvard Professor Alan Dershowitz, for-
mer Judge and then Pepperdine Law Dean Kenneth Starr,
former Deputy Assistant to the President and then Kirk-
land & Ellis Partner Jay Lefkowitz, and several others,
including prosecutors who had formerly worked in the
U.S. Attorney's Office and in the Child Exploitation and
Obscenity Section of the Justice Department. Defense
attorneys next requested a meeting with me to challenge
the prosecution and the terms previously presented by
the prosecutors in their meeting with Mr. Black. The
prosecution team and I met with defense counsel in Fall
2007, and I reaffirmed the office's position: two years,
registration and restitution, or trial.
Over the next several months, the defense team pre-
sented argument after argument claiming that felony
criminal proceedings against Epstein were unsupported
by the evidence and lacked a basis in law, and that the
office's insistence on jail-time was motivated by a zeal to
overcharge a man merely because he is wealthy. They
bolstered their arguments with legal opinions from
208
well-known legal expert
team warned me that th€
good man to serve time •
book if we continued tc
office systematically con!
ment, and when we di
appealed to Washington.
The defense strategy
Defense counsel investiga
their families, looking for
provide a basis for disqual
ecutor is an effective (thi
eliminating the individua
and thus most qualified to
lihood for success. Defensi
least two prosecutors. I
rejected, these arguments.
Despite the army of au
the terms first presented
meeting. On June 30, 2008
appeal to Washington D.(
guilty in state court. He NiNq
onment, register as a sexua
restitution to the victims.
Some may feel that the I
tougher. Evidence that has
encourage that view. Man;
out, filing detailed statemen
ages. Physical evidence has
these additional statements
2,
ATTERSON
FILTHY RICH
ecutors presented Epstein a
)us state felony charges (that
prisonment, registration as a
ation for the victims) or else
trial.
..ar-long assault on the prose-
. I use the word assault inten-
this case was more aggressive
prosecutors in my office, had
4r. Epstein hired an army of
'rofessor Alan Dershowitz, for-
-dine Law Dean Kenneth Starr,
3 the President and then Kirk-
_efkowitz, and several others,
o had formerly worked in the
in the Child Exploitation and
Justice Department. Defense
t meeting with me to challenge
terms previously presented by
meeting with Mr. Black. The
let with defense counsel in Fall
he office's position: two years,
n, or trial.
months, the defense team pre-
Lrgument claiming that felony
tinst Epstein were unsupported
ced a basis in law, and that the
time was motivated by a zeal to
ly because he is wealthy. They
nts with legal opinions from
208
well-known legal experts. One member of the defense
team warned me that the office's excess zeal in forcing a
good man to serve time in jail might be the subject of a
book if we continued to proceed with the matter. My
office systematically considered and rejected each argu-
ment, and when we did, my office's decisions were
appealed to Washington. As to the warning, I ignored it.
The defense strategy was not limited to legal issues.
Defense counsel investigated individual prosecutors and
their families, looking for personal peccadilloes that may
provide a basis for disqualification. Disqualifying a pros-
ecutor is an effective (though rarely used) strategy, as
eliminating the individuals most familiar with the facts
and thus most qualified to take a case to trial harms like-
lihood for success. Defense counsel tried to disqualify at
least two prosecutors. I carefully reviewed, and then
rejected, these arguments.
Despite the army of attorneys, the office held firm to
the terms first presented to Mr. Black in the original
meeting. On June 30, 2008, after yet another last minute
appeal to Washington D.C. was rejected, Epstein pled
guilty in state court. He was to serve 18 months impris-
onment, register as a sexual offender for life, and provide
restitution to the victims.
Some may feel that the prosecution should have been
tougher. Evidence that has come to light since 2007 may
encourage that view. Many victims have since spoken
out, filing detailed statements in civil cases seeking dam-
ages. Physical evidence has since been discovered. Had
these additional statements and evidence been known,
209
JAMES PATTERSON
the outcome may have been different. But they were not
known to us at the time.
A prosecution decision must be based on admissible
facts known at the time. In cases of this type, those are
unusually difficult because victims are frightened and
often decline to testify or if they do speak, they give con-
tradictory statements. Our judgment in this case, based
on the evidence known at the time, was that it was better
to have a billionaire serve time in jail, register as a sex
offender, and pay his victims restitution than risk a trial
with a reduced likelihood of success. I supported that
judgment then, and based on the state law as it then stood
and the evidence known at the time, I would support that
judgment again.
Epstein's treatment, while in state custody, likewise
may encourage the view that the office should have been
tougher. Although the terms of confinement in a state
prison are a matter appropriately left to the State of Flor-
ida, and not federal authorities, without doubt, the treat-
ment that he received while in state custody undermined
the purpose of a jail sentence.
Some may also believe that the prosecution should
have been tougher in retaliation for the defense's tactics.
The defense, arguably, often failed to negotiate in good
faith. They would obtain concessions as part of a negotia-
tion and agree to proceed, only to change their minds,
and appeal the office's position to Washington. The inves-
tigations into the family lives of individual prosecutors
were, in my opinion, uncalled for, as were the accusations
of bias and/or misconduct against individual prosecutors.
210
F:
At times, some prosecut
trial, and at times I felt t
right in the first meetin
spective of defense tacti
tional right to a defense
right should not be puni:
sel's exercise of their ri
Washington D.C. Proseci
frustration and anger wi
their judgment.
After the plea, I reca
One was from the FBI Sp(
to offer congratulations.
meetings regarding this c
of the defense, and he cat
holding firm against the 1
itz, Lefkowitz and Starr.
received calls or commun
itz, Lefkowitz and Starr. I
als previously, from my
Kirkland & Ellis in the m
peace. I agreed to talk an
Epstein pled guilty, as I tt
tors battle defense attorne
have tried, yet I confess ti:
fully in this case.
The bottom line is this:
served time in jail and is ni
He has been required to pa)
restitution clearly cannot c
'ATTERSON
n different. But they were not
must be based on admissible
1 cases of this type, those are
e victims are frightened and
they do speak, they give con-
• judgment in this case, based
:he time, was that it was better
time in jail, register as a sex
ms restitution than risk a trial
I of success. I supported that
on the state law as it then stood
: the time, I would support that
Idle in state custody, likewise
hat the office should have been
rms of confinement in a state
priately left to the State of Flor-
rities, without doubt, the treat-
le in state custody undermined
nce.
ve that the prosecution should
Iliation for the defense's tactics.
['ten failed to negotiate in good
concessions as part of a negotia-
:d, only to change their minds,
sition to Washington. The inves-
lives of individual prosecutors
ailed for, as were the accusations
:t against individual prosecutors.
210


FILTHY RICH
At times, some prosecutors felt that we should just go to
trial, and at times I felt that frustration myself. What was
right in the first meeting, however, remained right irre-
spective of defense tactics. Individuals have a constitu-
tional right to a defense. The aggressive exercise of that
right should not be punished, nor should a defense coun-
sel's exercise of their right to appeal a U.S Attorney to
Washington D.C. Prosecutors must be careful not to allow
frustration and anger with defense counsel to influence
their judgment.
After the plea, I recall receiving several phone calls.
One was from the FBI Special Agent-In-Charge. He called
to offer congratulations. He had been at many of the
meetings regarding this case. He was aware of the tactics
of the defense, and he called to praise our prosecutors for
holding firm against the likes of Messrs. Black, Dershow-
itz, Lefkowitz and Starr. It was a proud moment. I also
received calls or communications from Messrs. Dershow-
itz, Lefkowitz and Starr. I had known all three individu-
als previously, from my time in law school and at
Kirkland & Ellis in the mid 90s. They all sought to make
peace. I agreed to talk and meet with each of them after
Epstein pled guilty, as I think it important that prosecu-
tors battle defense attorneys in a case and then move on. I
have tried, yet I confess that this has been difficult to do
fully in this case.
The bottom line is this: Mr. Jeffrey Epstein, a billionaire,
served time in jail and is now a registered sexual offender.
He has been required to pay his victims restitution, though
restitution clearly cannot compensate for the crime. And
2/1
JAMES PATTERSON
we know much more today about his crimes because vic-
tims have come forward to speak out. Some may disagree
with prosecutorial judgments made in this case, but
those individuals are not the ones who at the time
reviewed the evidence available for trial and assessed the
likelihood of success.
• Respectfully,
R. Alexander Acosta
Former U.S. Attorney
Southern District of Florida
PATTERSON
7 about his crimes because vic-
speak out. Some may disagree
lents made in this case, but
,t the ones who at the time
ilable for trial and assessed the
PA i T
• Respectfully,
R. Alexander Acosta
Former U.S. Attorney
Southern District of Florida
212
ftermath
CHAPTER 56
Jeffrey Epstein: July 2009
Jeffrey Epstein walks out of the Stockade on July 21, 2009,
having served less than thirteen months of his eighteen-month
sentence. One of the concessions his lawyers have gotten
while working out his plea-deal guarantees is that the media not
be alerted to the time and day of his departure.
But from now on, Epstein, who is fifty-six, will carry the
mark of a level 3 sex offender—level 1 being the lowest, and
level 3 indicating the highest possible risk of a future criminal
act of a sexual nature. Wherever he goes, he will be forced to reg-
ister as such.
Every ninety days, Epstein will have to check in with the
authorities. Every year, the New York City Police Department
will take his mug shot. And for a full year, Epstein will be under
house arrest in Palm Beach.
This last prohibition doesn't stop him from flying, with court
215
JAMES PATTERSON
approval, on his own planes to New York and to Little Saint Jeff's,
where the locals have taken to referring to Epstein's 727 as the
Lolita Express.
There are other restrictions, of course, that Epstein is sup-
posed to abide by. He has to provide the state of Florida with a
list of all the motor vehicles, boats, and airplanes he owns. The
full list includes two Escalades, six Suburbans, two Ford F-150s,
two Harley-Davidsons, a Land Rover, a Hummer H2, a thirty-
four-foot JVC boat, and a thirty-five-foot Donzi powerboat.
Three of his five planes turn out to be registered to a com-
pany called Air Ghislaine, Inc.
As a registered sex offender, Epstein is legally obliged to
undergo psychiatric treatment. This is a restriction he'll get
around by having his own psychologist submit a report to law
enforcement officers.
Epstein is also prohibited from accessing pornography on
the Internet and using social networking for sexual purposes.
For Jeffrey Epstein, there will be no Bangbros, Tinder, or
Swingles. com.
There will be lawsuits.
Six weeks before probation ends, he settles with seven women
who sue him in civil court. But Epstein can easily afford the set-
tlement payments. He won't be going back to jail, and in regard
to further prosecution for any criminal actions, his troubles are
behind him.
Not everyone who's spent time in his company will be so
lucky.
216
Alfredo Rodriguez: Aug
E pstein's houseman, Al
prison sentence.
In a sworn statem
maid, Lupita, who had comi
up after Epstein's "massage5
lic, had cried as she describe
Rodriguez was fired by I
after seeing a strange car— g
As it turned out, the ca
masseuses.
On his way out of the hc
of Epstein's papers, which he
by Chief Reiter's investigator.
For years, Rodriguez tries
manager. No one wanted tc
IATTERSON
New York and to Little Saint Jeff's,
referring to Epstein's 727 as the
s, of course, that Epstein is sup-
rovide the state of Florida with a
oats, and airplanes he owns. The
, six Suburbans, two Ford F-150s,
1 Rover, a Hummer H2, a thirty-
-five-foot Donzi powerboat.
rn out to be registered to a corn-
ler, Epstein is legally obliged to
it. This is a restriction he'll get
ychologist submit a report to law
from accessing pornography on
.etworking for sexual purposes.
will be no Bangbros, Tinder, or
ends, he settles with seven women
it Epstein can easily afford the set-
e going back to jail, and in regard
• criminal actions, his troubles are
time in his company will be
216
CHAPTER 57
Alfredo Rodriguez: August 2009
Epstein's houseman, Alfredo Rodriguez, also ends up with a
prison sentence.
In a sworn statement, Rodriguez talks about Epstein's
maid, Lupita, who had complained to him about having to clean
up after Epstein's "massages." Lupita, who was a devout Catho-
lic, had cried as she described the stained towel and sex toys.
Rodriguez was fired by Epstein, he says, when he called 911
after seeing a strange car—a "beater" —in Epstein's driveway.
As it turned out, the car had belonged to one of Epstein's
masseuses.
On his way out of the house on El Brillo Way, he took some
of Epstein's papers, which he failed to produce when questioned
by Chief Reiter's investigators.
For years, Rodriguez tried and failed to find work as a house
nager. No one wanted to hire someone who'd worked for
217
JAMES PATTERSON
Jeffrey Epstein. Finally, desperately, he tried to sell the informa-
tion he'd stolen.
The papers named underage girls and the places where
Epstein had taken them. The list included locations in Califor-
nia, Paris, New Mexico, New York, and Michigan. The papers
also included the names, addresses, and phone numbers of
famous individuals—Henry Kissinger, Mick Jagger, Dustin Hoff-
man, Ralph Fiennes, David Koch, Ted Kennedy, Donald Trump,
Bill Richardson, Bill Clinton, and former Israeli prime minister
Ehud Barak among them.
This was intriguing, if not at all damning. Epstein made a
habit of collecting such information for future use. But informa-
tion pertaining to the girls would have bolstered the state's case
against Jeffrey Epstein, and by withholding it from the Palm
Beach PD and the FBI, Rodriguez had committed a crime.
In his defense, Rodriguez would say that the papers were an
"insurance policy." Without them, he believed, Epstein would
have made him "disappear."
But now Rodriguez needed the money. And so a few weeks
after Epstein's release from the Stockade, he approached a lawyer
who was representing some of Epstein's masseuses. He had the
"holy grail," he insisted. A• golden nugget." The names of hun-
dreds of girls, he said, who had been abused by Epstein.
The lawyer told Rodriguez in no uncertain terms that he was
obliged to turn whatever he had over to the authorities. By
demanding money for the information, Rodriguez was commit-
ting another crime.
According to a sworn statement by Christina Pryor, a special.
agent with the FBI, Rodriguez "persisted that he would only turn
over the information in his possession in exchange for $50,000."
218
Fr u.
Two months later, on Octobe.
who insisted once more on bi
lawyer told him that an associ
What the lawyer knew one
the associate in question was.
the FBI. A few days later, on I'
guez and sets up a meeting, wl
"During the meeting, Roc
book and several sheets of lega
ten notes," Special Agent Pryo
continues:
Rodriguez explained that he
his former employer's resid
2004 to 2005 and that the ho
working for his former emp
detail the information within
ant information to the UCE. I;
he had previously lied to the.
about the $50,000, took posse
counting it.
Rodriguez was then detai.
Proceedings, Title 18, U.S. Co
tioned. After Miranda warning
Rodriguez waived his rights a
those rights. Rodriguez admiti
and book in his possession an
to local law enforcement or th
21
?ATTERSON
FILTHY RICH
.ately, he tried to sell the informa-
rage girls and the places where
list included locations in Califor-
York, and Michigan. The papers
'dresses, and phone numbers of
:issinger, Mick Jagger, Dustin Hoff-
Dch, Ted Kennedy, Donald Trump,
and former Israeli prime minister
)t at all damning. Epstein made a
nation for future use. But informa-
Duld have bolstered the state's case
by withholding it from the Palm
;uez had committed a crime.
would say that the papers were an
them, he believed, Epstein would
ed the money. And so a few weeks
i.e Stockade, he approached a lawyer
of Epstein's masseuses. He had the
golden nugget." The names of hun-
ad been abused by Epstein.
!z in no uncertain terms that he was
le had over to the authorities. By
iformation, Rodriguez was commit
itement by Christina Pryor, a special
tz "persisted that he would only air, . .;
0
.ossession in exchange for $50,000." ...,. .)
218
* * *

Two months later, on October 28, the lawyer called Rodriguez,
who insisted once more on being paid for the information. The
lawyer told him that an associate would be in touch.
What the lawyer knew and Rodriguez did not know was that
the associate in question was an undercover employee (UCE) of
the FBI. A few days later, on November 2, the UCE calls Rodri-
guez and sets up a meeting, which takes place the following day.
"During the meeting, Rodriguez produced a small bound
book and several sheets of legal pad paper containing handwrit-
ten notes," Special Agent Pryor would say in her statement. She
continues:
Rodriguez explained that he had taken the bound book from
his former employer's residence while employed there in
2004 to 2005 and that the book had been created by persons
working for his former employer. Rodriguez discussed in
detail the information within the book and identified import-
ant information to the UCE. In addition, Rodriguez admitted
he had previously lied to the FBI. Rodriguez asked the UCE
about the $50,000, took possession of the money, and began
counting it.
Rodriguez was then detained for Obstruction of Official
Proceedings, Title 18, U.S. Code, Section 1512(c), and ques-
tioned. After Miranda warnings were administered by agents,
Rodriguez waived his rights and signed a written waiver of
those rights. Rodriguez admitted that he had the documents
and book in his possession and had never turned them over
to local law enforcement or the FBI. In addition, Rodriguez
219
JAMES PATTERSON
advised he had witnessed nude girls whom he believed were
underage at the pool area of his former employer's home,
knew that his former employer was engaging in sexual con-
tact with underage girls, and had viewed pornographic
images of underage girls on computers in his employer's
home. Rodriguez was then released from custody for further
investigation.
The items that Rodriguez had attempted to sell to the
UCE for $50,000.00 were reviewed by an agent familiar with
the underlying criminal investigation. As Rodriguez had
described, the items contained information material to the
underlying investigation that would have been extremely use-
ful in investigatang] and prosecuting the case, including the
names and contact information of material witnesses and
additional victims. Had those items been produced in
response to the inquiries of the state law enforcement officers
or the FBI Special Agents, their contents would have been
presented to the federal grand jury.
Following his release, Alfredo Rodriguez was arrested again.
He appeared in court on June 18, 2010, facing charges of cor-
ruptly concealing records and documents. Dressed in a blue
jumpsuit and shackles, he apologized for his crimes and asked
the court to be merciful.
He received a sentence of eighteen months.
It was the same punishment that Jeffrey Epstein had gotten
for his crimes. But unlike Epstein, Alfredo Rodriguez served his
time in a federal prison and did not ask for, or receive, permis-
sion to go on work release.
220
Prince Andrew: 2011
p rince Andrew also fares
imprisonment.
The two men are old I
Ghislaine Maxwell introduced]
time in the 1990s. In 2000, Eps
Castle to celebrate the queen's E
flew to Sandringham, the quee)
a party Prince Andrew threw for
The prince had also visited
Palm Beach as well as in New
Roberts made in her 2015 decla
asked her to give the prince Iv;
back with the details.
According to the Guardian,
tied together at Windsor Castle,

[admin]

***

HOUSE_OVERSIGHT_010560
txt
https://www.dropbox.com/scl/fo/9bq6uj0p ... tracking=1

79)Ao
ALLRED, MAROKO & GOLDBERG
NATHAN GOLDBERG*
MICHAEL MAROKO"
GLORIA R. ALLRED*t
JOHN S. WEST
DOLORES Y. LEAL
RENEE MOCHKATEL
MARGERY N. SOMERS
MARCUS SPIEGEL
CHRISTINA CHEUNGt
BYRON LAU
KIRBY F. CANON
* A PROFESSIONAL CORPORATION
t ALSO ADMITTED TO NEW YORK BAR
OALSO ADMITTED TO WASHINGTON DC BAR
A PARTNERSHIP OF PROFESSIONAL CORPORATIONS
6300 WILSHIRE BOULEVARD
SUITE 1500
LOS ANGELES, CALIFORNIA 90048
FAX
http://www.amglaw.com
VIA FEDERAL EXPRESS & EMAIL
Mr. Scott Link
Link & Rockenbach, PA
1555 Palm Beach Lakes Blvd., Suite 930
West Palm Beach, FL 33401
Re:
Dear Mr. Link,
June 19, 2019
OF COUNSEL
MARIA G. DEAZ
E-MAIL:
We represent with reference to her claims against Jeffrey Epstein
for childhood sexual abuse which occurred in New York City when she was years old.
New York recently passed the Child Victims Act which creates a 1 year window for
claims where the statute of limitations had expired. Therefore, will be able to sue
Mr. Epstein for the sexual abuse which she experienced while she was a minor.
was the perfect victim.
She was born in M, a town on the coast. When was four years
old, descended into civil war. At the age of six, her entire village was evacuated. She
fled her hometown travelling through war zones on foot with her family, in a stream of refugees.
Her family settled in the outskirts of . As refugees, with no money, her family
lived together in one room, sharing a bathroom with other families. Her parents eventually
found low paying, unskilled jobs. Their only clothing was what was provided to them by the
Red Cross.
When she was ten years old,
family arrived in
By the sixth grade, was 5'10", beautiful and naturally slim. She desperately
NEW YORK OFFICES I 305 BROADWAY, SUITE 607 I NEW YORK, NEW YORK 10007
T (212) 202-2966 I FAX (212) 202-2967
HOUSE OVERSIGHT 010560
Scott Link
June 19, 2019
Page 2
wanted to leave She learned about a talent search for models and persuaded her
mother to take her. She was a huge success and began modeling at age fourteen. Though her
parents disparaged her for marketing her appearance, they allowed her to work because she
earned more than their combined income.
At age sixteen, moved to New York City to model. She lived in an
apartment for models, with one or two roommates and no adult on the premises. Her father was
deeply ashamed of her because he disapproved of her profession and her parents distanced
themselves.
days were hectic with professional assignments. She worked with top tier
clients and for DNA Modeling Agency, a well-known agency representing supermodels such as
Linda Evangelista and Natalia Vodianova.
was very innocent and inexperienced prior to meeting Mr. Epstein. At age
sixteen, experienced her first kiss. The director of a perfume campaign, Fabian
Barron, wanted a kiss at the end of the commercial as a finale to a perfume ad. She dreaded her
parents' reaction to seeing the commercial. She was raised in the Orthodox Christian Church
where abstinence was encouraged.
met Jeffrey Epstein when was sixteen years old. She was introduced
through a fellow model a few years her senior.
Mr. Epstein seemed bigger than life. He did not drink or do drugs, which put her at ease.
He was friends with former President Bill Clinton, the President who made it possible for ME
and her family to immigrate to America. When she told Mr. Epstein how her family
came to America, Mr. Epstein said he would personally thank "Bill" for her. Mr. Epstein touted
other impressive connections. He made it known that he had A list celebrities on speed-dial.
She felt very fortunate to have made the connection with Mr. Epstein.
As s estrangement from her family increased, Mr. Epstein's role in her life
became more and more important. He encouraged her and built her confidence. She trusted him
completely.
Mr. Epstein told hat he was on the board of directors at Harvard
University. He promised that once she took her SATs and obtained the scores she needed, he
would write a letter of recommendation for her, which he said would carry significant weight
with regard to her admission. Her dream was to establish herself as a successful model and to
one day graduate from Harvard. Mr. Epstein made her feel that everything she wanted was
possible.
HOUSE OVERSIGHT 010561
Scott Link
June 19, 2019
Page 3
confided to him that she had never even had a boyfriend. He told her
everything would fall into place, "just keep doing what you are doing, work hard and stay
focused." She told Mr. Epstein that she preferred to abstain from sex until she was married.
The first time asked her for a massage was to help with an ache in his
shoulder. thought it was an innocent request. He said his masseuse had failed to
get a kink out of his shoulder. He gave her a large purple massager for her to use to take the knot
out of his back. Mr. Epstein told her she was an excellent masseuse and she was pleased to be
able to ease his pain.
When the massage ended, Mr. Epstein pulled two hundred dollars from his wallet and
handed it to her. He said, "I was going to give it to the masseuse anyway, so you take it and pay
for your car service or something."
Mr. Epstein began calling her every day, no matter where she was in the world. He told
her he loved her. He became a vital part of_________________Iworld as her parents remained
distant. He invited her to stay at one of his apartments close to him on the Upper East Side. Her
arduous work schedule, starting with 6:00 a.m. call times and shows running late into the night
were exhausting. Epstein's daily check-up calls and pep talks gave her strength to survive her
grinding schedule.
When in Paris, Mr. Epstein allowed her to stay at his home with her sister and arranged
for a night out at a concert with Naomi Campbell. It appeared to that Mr. Epstein's
thoughts were focused on her career, future and good fortune.
The first time the purple massage tool found its way between her legs, told
him to stop, but Mr. Epstein pushed the head of the massager firmly against her and forced her
legs apart. She felt ashamed and embarrassed. The massages became a ritual and were always
accompanied with sexual abuse and a two-hundred dollar payment at the end.
Mr. Epstein approached her as if he was her mentor and teacher, teaching her about
sexuality, opening her eyes. She experienced immense orgasms, and then shame and fear. She
felt claustrophobia as she stared up into Mr. Epstein's church-like ceiling of the massage parlor
while he fondled her. She felt she couldn't escape her position, and that this was the way it had
to be because this powerful man orchestrated it. At the end of each massage he would make
himself ejaculate by demanding she pay vigorous attention to his nipples with her fingers and he
would tell her what a good girl she was, that he loved her and would call her later, which made
everything seem better. Then he would open his wallet filled with hundred dollar bills and give
her a couple, which she accepted as pocket money, never thinking twice about it.
HOUSE OVERSIGHT 010562
Scott Link
June 19, 2019
Page 4
thought this is what it must feel like to become a woman. She was both
thrilled and ashamed. She followed the path that Mr. Epstein set out for her because he said if
she trusted him and did what he told her to do, everything would go according to his plan and her
career would soar. Without him the world was a scary and unpredictable place. When she was
with him, she felt like everything was right because of how much love and care she received
from him. She started to think and believe that they would be together and that he would marry
her.
He used the purple massage vibrator on her time and time again. She closed her eyes
feeling lost, overwhelmed and out of control.
When he stuck his penis in her mouth, she did what she was told. She choked and
gagged and when she tried to move her head away he forced it back into place. Mr. Epstein was
extremely aggressive. When it was over he told her how amazing she was. She continued to
believe in Mr. Epstein's friendship and guidance.
Mr. Epstein took her virginity. This was the trajectory for which he groomed her. =
first sexual experience was devoid of tenderness or affection. She was stripped down
and made to shower. Mr. Epstein told her, "If you're lying about being a virgin, or I get a
disease from you, I'll kill you." She felt her mind separate from her body during intercourse.
She began to feel like a shell of her former self. She was mortified and in agony. She
felt she had become everything her parents feared she would become. She was appearing in
beauty magazines and making hundreds of thousands of dollars, but felt dirty and worthless. Mr.
Epstein made her feel like nothing more than a teenage prostitute. Everything came crashing
down once she realized that this was not love.
left Mr. Epstein's residence for the last time feeling less than human. On
her way out, she passed a young girl who appeared to be another young model. As
turned around to glance back, she saw the young woman entering Mr. Epstein's residence. She
was disgusted with the realization that she was one of many called to "massage" Epstein.
had a nervous breakdown while alone in New York. She found herself
crying inconsolably, shaking, hyperventilating and unable to go to her castings and meetings.
She was suicidal. She feared confiding in her agents and reaching out for help from them
because she was so ashamed. She booked a ticket to go home.
She flew back to Kansas where her parents were living. She never returned to New York.
was devastated with the realization of what she was lured into and how she
HOUSE OVERSIGHT 010563
Scott Link
June 19, 2019
Page 5
had been victimized. It shattered her to her core. At the vulnerable age of 16, Mr. Epstein made
himself the center of her existence and the master of her world. She realized she was a
disposable pawn in his game. She could not talk about her years with Mr. Epstein because she
was consumed with shame. At 16 years old, he isolated her and made himself her only
emotional support system. Her mental torment and pain turned into depression. She was
prescribed medication. She numbed herself and tried not to deal with what had happened. She
tried to block the pain.
____________was embarrassed that she had been used and abused. She withdrew and had
no desire to model or interact with anyone in the modeling world anymore.
stopped taking calls from modeling agencies, and eventually they stopped calling for good. She
was afraid to go to New York where her emotions and memories would be triggered.
The final contact between and Mr. Epstein was when he tracked her
parent's house phone number in Kansas and tried to speak to her. mother
grabbed the phone and told Mr. Epstein she was calling the police before hanging up on him.
Her career dwindled to nothing. Taking a break from the modeling industry when clients
like Italian Vogue and Victoria's Secret were requesting bookings constituted career suicide.
In Kansas she became chronically depressed. She was suicidal before her 18th birthday.
She called the suicide hotline many times from her home.
While in Kansas, a friend of________________ent her an email with news that Mr. Epstein
had been arrested for trafficking underaged girls. felt as if she had gone from
being a supermodel to becoming an unsuspecting prostitute. Her parents' warnings of what
would become of her in New York had come to fruition. She fell prey to a child predator, Mr.
Epstein, and it took her a decade to understand the gravity of what Epstein had done to her as a
vulnerable young girl.
Mr. Epstein mas ueraded as a loving mentor, a parental substitute and friend who had
nothing bul best interest in mind. The repercussions of the sexual and mental
abuseendured remain with her. Her first sexual encounters are forever scarred by
memories of Mr. Epstein forcing his purple massage device between her legs amidst her cries for
him to stop. Debilitating nausea and stomach pain followed her separation from him. She had
no framework with which to reference what a "normal" sexual experience was. She remains
plagued with self-doubt and insecurity and finds it nearly impossible to separate memories of
Mr. Epstein's manipulation and abuse from new relationships she tries to develop.
HOUSE OVERSIGHT 010564
Scott Link
June 19, 2019
Page 6
The sexual abuse Mr. Epstein inflicted upon left irreparable psychological
scars. She has struggled and continues to struggle with her ability to maintain healthy
relationships with men and in general. Her career is permanently compromised and the
likelihood of recovering severed professional ties is non-existent.
Please contact us within ten days of this letter to advise whether Mr. Epstein is amenable
to attempting to resolve 's civil claims without litigation.
Very truly yours,
ALLRED, MAROKO & GOLDBERG
HOUSE OVERSIGHT 010565

***

HOUSE_OVERSIGHT_010566
txt
https://www.dropbox.com/scl/fo/9bq6uj0p ... tracking=1

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No. :50 2009 CA 040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants,
STATEMENT OF UNDISPUTED FACTS
Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed
material facts in this case. Each of the following facts is numbered separately and individually to
facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall
identify . . . any summary judgment evidence on which the adverse party relies."). All
referenced exhibits and attachments have previously been filed with the Court and provided to
Epstein.
Sexual Abuse of Children By Epstein
1. Defendant Epstein has a sexual preference for young children. Deposition of
Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment
#1).1
When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to
remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the
adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to
him. "[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to
2. Epstein repeatedly sexually assaulted more than forty (40) young girls on
numerous occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These
sexual assaults included vaginal penetration. Epstein abused many of the girls dozens if not
hundreds of times. Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex
with females under the age of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane
Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at
least 17 times by Epstein) (hereinafter "Jane Doe Depo") (Deposition Attachment #2); id. 564-67
(vaginal penetration by Epstein with his finger), 568 (vaginal penetration by Epstein with a
massager); Deposition of L.M., September 24, 2009, at 73 (hereinafter "L.M. Depo")
(Deposition Attachment #3) (describing the manner in which Epstein abused her beginning when
LM was 13 years old, touching her vagina with his fingers and vibrator) at 74, line 12-13 (she
was personally molested by Epstein more than 50 times), at 164, line 19-23 and 141, line 12-13
and 605, line 3-6 (describing that in addition to being personally molested by Epstein she was
paid $200 per underage girl she brought Epstein and she brought him more than seventy (70)
underage girls - she told him that she did not want to bring him any more girls and he insisted
that she continue to bring him underage girls); Deposition of E.W., May 6, 2010 (hereinafter
"E.W. Depo") (Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse
of her beginning at age 14 when he paid her for touching her vagina, inserting his fingers and
civil actions when they refuse to testify in response to probative evidence offered against them." Baxter
v. Paltnigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App.
2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of
others and then escape the consequences by invoking a constitutional privilege — at least not in a civil
setting." Fraser v. Security and II1V. Corp., 615 So.2d 841, 842 (Fla. App. 1993).
2
using a vibrator and he also paid her $200 for each other underage female E.W. brought him to
molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date
(hereinafter "Jane Doe #4 Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes
first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on
[me], grabbing my nipples, smelling my butt, jerking off in front of me, licking my cut, several
times.").
3. At all relevant times Edwards has had a good faith basis to conclude and did
conclude2 that Epstein was able to access a large number of underage girls through a pyramid
abuse scheme in which he paid underage victims $200-$300 cash for each other underage victim
that she brought to him. See Palm Beach Police Incident Report at 87 (hereinafter "Incident
Report") (Exhibit "A").3 The Palm Beach Police Incident Report details Epstein's scheme for
molesting underage females. Among other things, the Incident Report outlines some of the
experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to
Epstein's home, she was taken upstairs by a woman she believed to be Epstein's assistant. The
woman started to fix up the room, putting covers on the massage table and bringing lotions out.
The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein
walked over to S.G. and told her to take her clothes off in a stern voice. S.G. states in the report
she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her
bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving
2 In support of all assertions concerning the actions Edwards took, what Edwards learned in the course of his
representation of his clients, Edwards's good faith beliefs and the foundation for those beliefs, see Edwards
Affidavit and specifically paragraphs 25 and 25 of that Affidavit.
3 For clarity, depositions attached to this memorandum will be identified numerically as attachments #I, #2, #3, etc.,
while exhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc.
3
on her thong panties. Epstein then instructed S.G to give him a massage. As S.G gave Epstein a
massage, Epstein turned around and masturbated. S.G. was so disgusted, she did not say
anything; Epstein told her she "had a really hot body." Id. at 14. In the report, S.G. admitted
seeing Jeffrey Epstein's penis and stated she thought Epstein was on steroids because he was a
"really built guy and his wee wee was very tiny." Id. at 15.
4. The exact number of minor girls who Epstein assaulted is known only to Epstein.
However, Edwards had a good faith basis to believe and did in fact believe that Epstein's victims
were substantially more than forty (40) in number. In addition to the deposition excerpts from
two of his many victims above about the number of underage girls brought to Epstein and the
Palm Beach incident report, there is overwhelming proof that the number of underage girls
molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v.
Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B"); see also Deposition of Jeffrey
Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking the 5th on questions about his
daily abuse and molestation of children) (Deposition Attachment #6).
5. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that Epstein and his attorneys knew of the seriousness of the criminal investigation
against him and corresponded constantly with the United States Attorney's Office in an attempt
to avoid the filing of numerous federal felony offenses, which effort was successful. See
Correspondence from U.S. Attorney's Office to Epstein (hereinafter "U.S. Attorney's
Correspondence") (Composite Exhibit "C) (provided in discovery during the Jane Doe v. Epstein
case).
4
6. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that, more specifically, Epstein's attorneys knew of Epstein's scheme to recruit minors for
sex and also knew that these minors had civil actions that they could bring against him. In fact,
there was much communication between Epstein's attorneys and the United States Prosecutors in
a joint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant
U.S. Attorney Marie Villafaila sent an email (attached hereto as Exhibit "D") to Jay Leflcowitz,
counsel for Epstein, with attached proposed letter to special master regarding handling numerous
expected civil claims against Epstein. The letter reads in pertinent part,
"The undersigned, as counsel for the United States of America and
Jeffrey Epstein, jointly write to you to provide information relevant to your
service as a Special Master in the selection of an attorney to represent several
young women who may have civil damages claims against Mr. Epstein. The
U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred
to as the "United States") have conducted an investigation of Jeffrey Epstein
regarding his solicitation of minor females in Palm Beach County to engage in
prostitution. Mr. Epstein, through his assistants, would recruit underage
females to travel to his home in Palm Beach to engage in lewd conduct in
exchange for money. Based upon the investigation, the United States has
identified forty (40) young women who can be characterized as victims
pursuant to 18 USC 2255. Some of those women went to Mr. Epstein's home
only once, some went there as much as 100 times or more. Some of the
women's conduct was limited to performing a topless or nude massage while
Mr. Epstein masturbated himself. For other women, the conduct escalated to
full sexual intercourse. As part of the resolution of the case, Epstein has
agreed that he would not contest jurisdiction in the Southern District of Florida
for any victim who chose to sue him for damages pursuant to 18 USC 2255.
Mr. Epstein agreed to provide an attorney for victims who elected to proceed
exclusively pursuant to that section, and agreed to waive any challenge to
liability under that section up to an amount agreed to by the parties. The parties
have agreed to submit the selection of an attorney to a Special Master...."
7. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that L.M. was, in fact, a victim of Epstein's criminal abuse because L.M. was one of the
5
minor females that the United States Attorney's Office recognized as a victim. L.M. 's sworn
deposition testimony and the adverse inference drawn from Epstein's refusal to testify confiuiii
that Epstein began sexually assaulting L.M. when she was 13 years old and continued to molest
her on more than fifty (50) occasions over three (3) years. Epstein Depo., Attachment #1, at 17
("Q: Did you . . . ever engage in any sexual conduct with L.M.?" A: [Invocation of the Fifth
Amendment].); see also Epstein Depo., April 14, 2010, Attachment #6, at 456 ("Q: LM was an
underage female that you first abused when she was 13 years old; is that correct?" A: [Invocation
of Fifth Amendment].)
8. Epstein was also given ample opportunity to explain why he engaged in sexual
activity with L.M. beginning when L.M. was 13 years old and why he has molested minors on an
everyday basis for years, and he invoked his 5th amendment right rather than provide
explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition
Attachment # 7).
9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and
did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216.
10. Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse
began when Jane Doe was 14 years old. Rather than incriminate himself', Epstein invoked the
5th amendment to questions about him digitally penetrating Doe's vagina, using vibrators on her
vagina and masturbating and ejaculating in her presence. Epstein Depo., April 14, 2010,
Attachment #6, at 420, 464, 468.
11. When Edwards's clients L.M., E.W., and Jane Doe were 13 or 14 years old, each
was brought to Epstein's home multiple times by another underage victim. Epstein engaged in
6
one or more of the following acts with each of the then-minor girls at his mansion: receiving a
topless or completely nude massage; using a vibrator on her vagina; masturbating in her
presence; ejaculating in her presence; touching her breast or buttocks or vagina or the clothes
covering her sexual organs; and demanding that she bring him other underage girls. Epstein and
his co-conspirators used the telephone to contact these girls to entice or induce them into going
to his mansion for sexual abuse. Epstein also made E.W. perform oral sex on him and was to
perfoim sex acts on Nadia Marcinkova (Epstein's live-in sex slave) in Epstein's presence. See
Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane
Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice")
(Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-380; L.M. Depo., Attachment #3, at 416;
E.W. Depo, Attachment #4, at 205.
12. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was
approximately 15 years old, C.L. was brought to Epstein's home by another underage victim.
While a minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or
more of the following acts with her while she was a minor at his house - topless or completely
nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her
presence; Epstein ejaculated in her presence; Epstein also demanded that she bring him other
underage girls. See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A."
13. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that yet another girl Epstein sexually assault was A.H. When she was approximately 16
years old, she was brought to Epstein's home by another underage victim. While a minor, she
7
was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following
acts with her while she was a minor at his house - topless or completely nude massage on
Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein
ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes
covering her sexual organs; was made to perform sex acts on Epstein; made to perfoim sex acts
on Nadia Marcinkova in Epstein's presence. Epstein also forcibly raped this underage victim, as
he held her head down against her will and pumped his penis inside her while she was screaming
"No". See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A", at 41 (specifically
discussing the rape):
"[A.H.] remembered that she climaxed and was removing herself from the
massage table. [A.H.] asked for a sheet of paper and drew the massage table in the
master bathroom and where Epstein, Marcinkova and she were. Epstein turned
[A.H.] on to her stomach on the massage bed and inserted his penis into her
vagina. [A.H.] stated Epstein began to pump his penis in her vagina. [A.H.]
became upset over this. She said her head was being held against the bed forcibly,
as he continued to pump inside her. She screamed no, and Epstein stopped ...."
"[A.H.] advised there were times that she was so sore when she left Epstein's
house. [A.H.] advised she was ripped, torn, in her vagina area. [A.H.] advised she
had difficulty walking to the car after leaving the house because she was so sore."
14. Without detailing each fact known about Epstein's abuse of the many underage
girls, Edwards has had a good faith basis to believe and did in fact believe at all relevant times
that Epstein also abused other victims in ways closely similar to those described in the preceding
paragraphs. Epstein's additional victims include the following (among many other) young girls:
S.G.; A.D.; V.A.; N.R.; J.S.; V.Z.; J.A.; F.E.; M.L.; M.D.; D.D.; and D.N. These girls were
between the ages of 13 and 17 when Epstein abused them. See Rule 413 Notice, Exhibit E;
Deposition of E.W., Deposition Attachment #4.
8
15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw
numerous underage girls coming into Epstein's mansion for purported "massages." See
Rodriguez Depo. at 242-44 (Deposition Attachment #8). Rodriguez was aware that "sex toys"
and vibrators were found in Epstein's bedroom after the purported massages. Id. at 223-28.
Rodriguez thought what Epstein was doing was wrong, given the extreme youth of the girls he
saw. Id. at 230-31.
16. Alfredo Rodriguez took a journal from Epstein's computer that reflected many of
the names of underage females Epstein abused across the country and the world, including
locations such as Michigan, California, West Palm Beach, New York, New Mexico, and Paris,
France. See Journal (hereinafter "The Journal" or "Holy Grail") (Exhibit "F") (identifying,
among other Epstein acquaintances, females that Rodriguez believes were underage under the
heading labeled "Massages").
17. Rodriguez was later charged in a criminal complaint with obstruction of justice in
connection with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases
against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at
2, U.S. v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez
stated he needed money because the journal was his "property" and that he was afraid that
Jeffrey Epstein would make him "disappear" unless he had an "insurance policy" (i.e., the
journal). Id. at 3. Because of the importance of the information in the journal to the civil cases,
Mr. Rodriguez called it "The Holy Grail."
18. In the "Holy Grail" or "The Journal," among the many names listed (along with
the abused girls) are some of the people that Epstein alleges in his Complaint had "no connection
9
whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump);
at 9 (Bill Clinton phone numbers listed under "Doug Bands").
Federal Investigation and Plea Agreement With Epstein
19. In approximately 2005, the FBI and the U.S. Attorney's Office in the Southern
District of Florida learned of Epstein's repeated sexual abuse of minor girls. They began a
criminal investigation into federal offenses related to his crimes. See U.S. Attorney's
Correspondence, Exhibit "C".
20. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe that to avoid the Government learning about his abuse of minor girls, Epstein threatened
his employees and demanded that they not cooperate with the government. Epstein's aggressive
witness tampering was so severe that the United States Attorney's Office prepared negotiated
plea agreements containing these charges. For example, in a September 18, 2007, email from
AUSA Villafacia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea
agreement describing Epstein's witness tampering as follows:
"UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER"
On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason
Richards traveled to the home of Leslie Groff to serve her with a federal grand
jury subpoena with an investigation pending in the Southern District of Florida.
Ms. Groff works as the personal assistant of the defendant. Ms. Groff began
speaking with the agents and then excused herself to go upstairs to check on her
sleeping child. While upstairs, Ms. Groff telephoned the defendant, Jeffrey
Epstein, and informed him that the FBI agents were at her home. Mr. Epstein
instructed Ms. Groff not to speak with the agents and reprimanded her for
allowing them into her home. Mr. Epstein applied pressure to keep Ms. Groff
from complying with the grand jury subpoenas that the agents had served upon
her. In particular, Mr. Epstein warned Ms. Groff against turning over documents
and electronic evidence responsive to the subpoena and pressured her to delay her
10
appearance before the grand jury in the Southern District of Florida. This
conversation occurred when Mr. Epstein was aboard his privately owned civilian
aircraft in Miami in the Southern District of Florida. His pilot had filed a flight
plan showing the parties were about to return to Teterboro, NJ. After the
conversation with Ms. Groff, Mr. Epstein became concerned that the FBI would
try to serve his traveling companion, Nadia Marcinkova, with a similar grand jury
subpoena. In fact, the agents were preparing to serve Ms. Marcinkova with a
target letter when the flight landed in Teterboro. Mr. Epstein then redirected his
airplane, making the pilot file a new flight plan to travel to the US Virgin Islands
instead of the New York City area, thereby keeping the Special Agents from
serving the target letter on Nadia Marcinkova. During the flight, the defendant
verbally harassed Ms. Marcinkova, harassing and pressuring her not to cooperate
with the grand jury's investigation, thereby hindering and dissuading her from
reporting the commission of a violation of federal law to a law enforcement
officer, namely, Special Agents of the FBI. Epstein also threatened and harassed
Sarah Kellen against cooperating against him as well.
21. Edwards learned that the Palm Beach police department investigation ultimately
led to the execution of a search warrant at Epstein's mansion in October 2005. See Police
Incident Report, Exhibit "A".
22. Edwards learned that at around the same time, the Palm Beach Police Department
also began investigating Epstein's sexual abuse of minor girls. They also collected evidence of
Epstein's involvement with minor girls and his obsession with training sex slaves, including
pulling information from Epstein's trash. Their investigation showed that Epstein ordered from
Arnazon.com on about September 4, 2005, such books as: SM101: A Realistic Introduction, by
Jay Wiseman; SlaveCraft: Roadmaps for Erotic Servitude - Principles, Skills, and Tools, by Guy
Baldwin; and Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners,
by Christina Abernathy. See Receipt for Sex Slave Books (Exhibit "I").
23. The Palm Beach incident reports provided Edwards with the names of numerous
witnesses that participated in Epstein's child molestation criminal enterprise and also provided
11
Edwards with some insight into how far-reaching Epstein's power was and how addicted Epstein
was to sex with children. See Incident Report, Exhibit "A".
24. The Palm Beach Police Department also collected Epstein's message pads, which
provided other names of people that also knew Epstein's scheme to molest children. See
Message Pads (Exhibit "J") (note: the names of underage females have been redacted to protect
the anonymity of the underage sex abuse victims). Those message pads show clear indication
that Epstein's staff was frequently working to schedule multiple young girls between the ages of
12 and 16 years old literally every day, often two or three times per day. Id.
25. In light of all of the infatuation of numerous crimes committed by Epstein,
Edwards learned that the U.S. Attorney's Office began preparing the filing of federal criminal
charges against Epstein. For example, in addition to the witness tampering and money
laundering charges the U.S. Attorney's Office prepared an 82-page prosecution memo and a 53-
page indictment of Epstein related to his sexual abuse of children. On September 19, 2007, at
12:14 PM, AUSA Villafafia wrote to Epstein's counsel, Jay Lefkowitz, "Jay - I hate to have to be
firm about this, but we need to wrap this up by Monday. I will not miss my indictment date
when this has dragged on for several weeks already and then, if things fall apart, be left in a less
advantageous position than before the negotiations. I have had an 82-page pros memo and 53-
page indictment sitting on the shelf since May to engage in these negotiations. There has to be
an ending date, and that date is Monday." These and other communications are within the
correspondence attached as Composite Exhibit "C."
26. Edwards learned that rather than face the filing of federal felony criminal charges,
Epstein (through his attorneys) engaged in plea bargain discussions. As a result of those
12
discussions, on September 24, 2007, Epstein signed an agreement with the U.S. Attorney's
Office for the Southern District of Florida. Under the agreement, Epstein agreed to plead guilty
to an indictment pending against him in the 15th Judicial Circuit in and for Palm Beach County
charging him with solicitation of prostitution and procurement of minors for prostitution.
Epstein also agreed that he would receive a thirty month sentence, including 18 months of jail
time and 12 months of community control. In exchange, the U.S. Attorney's Office agreed not to
pursue any federal charges against Epstein. See Non-Prosecution Agreement (Exhibit "K").
27. Part of the Non-Prosecution Agreement that Epstein negotiated was a provision in
which the federal government agreed not to prosecute Epstein's co-conspirators. The co-
conspirators procured minor females to be molested by Epstein. One of the co-conspirators -
Nadia Marcinkova -even participated in the sex acts with minors (including E.W.) and Epstein.
See Incident Report, Exhibit "A", at 40-42, 49-51; Deposition of Nadia Marcinkova, April 13,
2010, (hereinafter "Marcinkova Depo.") at 11 (Deposition attachment #9).
28. Under the Non-Prosecution Agreement, Epstein was to use his "best efforts" to
enter into his guilty pleas by October 26, 2007. However, Edwards learned that Epstein violated
his agreement with the U.S. Attorney's Office to do so and delayed entry of his plea. See Letter
from U.S. Attorney R. Alexander Acosta to Lilly Ann Sanchez, Dec. 19, 2007 (Exhibit "L").
29. On January 10, 2008 and again on May 30, 2008 E.W. and L.M. received letters
from the FBI advising them that "[t]his case is currently under investigation. This can be a
lengthy process and we request your continued patience while we conduct a thorough
investigation." Letters attached at Composite Exhibit "M". This document is evidence that the
FBI did not notify E.W. and L.M. that a plea agreement had already been reached that would
13
block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of
the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M.
about the plea. See id.
30. In 2008, Edwards believed in good faith that criminal prosecution of Epstein was
extremely important to his clients E.W. and L.M. and that they desired to be consulted by the
FBI and/or other representatives of the federal government about the prosecution of Epstein.
The letters that they had received around January 10, 2008, suggested that a criminal
investigation of Epstein was on-going and that they would be contacted before the federal
government reached any final resolution of that investigation. See id.
Edwards Agrees to Serve as Legal Counsel for Three Victims of Epstein 's Sexual
Assaults
31. In about April 2008, Bradley J. Edwards, Esq., was a licensed attorney in Florida,
practicing as a sole practitioner. As a fornler prosecutor, he was well versed in civil cases that
involved criminal acts, including sexual assaults. Three of the many girls Epstein had abused —
L.M., E.W., and Jane Doe — all requested that Edwards represent them civilly and secure
appropriate monetary damages against Epstein for repeated acts of sexual abuse while they were
minor girls. Two of the girls (L.M. and E.W.) also requested that Edwards represent them in
connection with a concern that the Federal Bureau of Investigation (FBI) and U.S. Attorney's
Office might be arranging a plea bargain for the criminal offenses committed by Epstein without
providing them the legal rights to which they were entitled (including the right to be notified of
plea discussions and the right to confer with prosecutors about any plea arrangement). See
14
Affidavit of Bradley J. Edwards, Esq. at ¶1 - 2, ¶4 (hereinafter "Edwards Affidavit") (Exhibit
32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008,
attorney Edwards agreed to represent Jane Doe; and, on July 7, 2008, attorney Edwards agreed to
represent L.M. in connection with the sexual assaults committed by Epstein and to insure that
their rights as victims of crimes were protected in the criminal process on-going against Epstein.
Mr. Edwards and his three clients executed written retention agreements. See id. at ¶2.
33. In mid June of 2008, Edwards contacted AUSA Villafeia to infoiin her that he
represented Jane Doe #1 and, later, Jane Doe #2. AUSA Villafalia did not advise that a plea
agreement had already been negotiated with Epstein's attorneys that would block federal
prosecution. To the contrary, AUSA Villafalia mentioned a possible indictment. AUSA
Villafafia did indicate that federal investigators had concrete evidence and infoimation that
Epstein had sexually molested many underage minor females, including E.W., LM, and Jane
Doe. See id. at ¶4.
34. Edwards also requested from the U.S. Attorney's Office the infoimation that they
had collected regarding Epstein's sexual abuse of his clients. However, the U.S. Attorney's
Office, declined to provide any such infoiniation to Edwards. It similarly declined to provide
any such information to the other attorneys who represented victims of Epstein's sexual assaults.
At the very least, this includes the items that were confiscated in the search warrant of Epstein's
home, including dildos, vibrators, massage table, oils, and additional message pads. See
Property Receipt (Exhibit "0").
15
35. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaiia received a
copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30
a.m., Monday, June 30, 2008. AUSA Villafalia called Edwards to provide notice to his clients
regarding the hearing. AUSA Villafafia did not tell Attorney Edwards that the guilty pleas in
state court would bring an end to the possibility of federal prosecution pursuant to the plea
agreement. See Edwards Affidavit, Exhibit "N", at ¶6.
36. Under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, victims of
federal crimes — including E.W. and L.M. — are entitled to basic rights during any plea
bargaining process, including the right to be treated with fairness, the right to confer with
prosecutors regarding any plea, and the right to be heard regarding any plea. The process that
was followed leading to the non-prosecution of Epstein violated these rights of E.W. and L.M.
See Emergency Petn. for Victim's Enforcement of Crime Victim's Rights, No. 9:08-CV-80736-
KAM (S.D. Fla. 2008) (Exhibit "P").
37. Because of the violation of the CVRA, on July 7, 2008, Edwards filed an action in
the U.S. District Court for the Southern District of Florida, Case No. 9:08-CV-80736, seeking to
enforce the rights of E.W. and L.M. That action alleged that the U.S. Attorney's Office had
failed to provide E.W. and L.M. the rights to which they were entitled under the Act, including
the right to be notified about a plea agreement and to confer with prosecutors regarding it. See
Id.
38. On July 11, 2008, Edwards took E.W. and L.M. with him to the hearing on the
CVRA action. It was only at this hearing that both victims learned for the first time that the plea
deal was already done with Epstein and that the criminal case against Epstein had been
16
effectively terminated by the U.S. Attorney's office. See Hearing Transcript, July 11, 2008
(Exhibit "Q").
39. Edwards learned that Jane Doe felt so strongly that the plea bargain was
inappropriate that she made her own determination to appear on a television program and
exercise her First Amendment rights to criticize the unduly lenient plea bargain Epstein received
in a criminal case.
40. The CVRA action that Edwards filed was recently administratively closed and
Edwards filed a Motion to reopen that proceeding. See No. 9:08-CV-80736 (S.D. Fla.).
Epstein 's Entry of Guilty Pleas to Sex Offenses
41. Ultimately, on June 30, 2008, in the Fifteenth Judicial Circuit in Palm Beach
County, Florida, defendant Epstein, entered pleas of "guilty" to various Florida state crimes
involving the solicitation of minors for prostitution and the procurement of minors for the
purposes of prostitution. See Plea Colloquy (Exhibit "R").
42. As a condition of that plea, and in exchange for the Federal Government not
prosecuting the Defendant, Epstein additionally entered into an agreement with the Federal
Government acknowledging that approximately thirty-four (34) other young girls could receive
payments from him under the federal statute providing for compensation to victims of child
sexual abuse, 18 U.S.C. § 2255. As had been agreed months before, the U.S. Attorney's Office
did not prosecute Epstein federally for his sexual abuse of these minor girls. See Addendum to
Non-Prosecution Agreement (Exhibit "5") (in redacted form to protect the identities of the
minors involved).
17
43. Because Epstein became a convicted sex offender, he was not to have contact
with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach
Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or
indirect" with any victims. She also expressly stated that her no-contact order applied to "all of
the victims." Similar orders were entered by the federal court handling some of the civil cases
against Epstein. The federal court stated that it "finds it necessary to state clearly that Defendant
is under this court's order not to have direct or indirect contact with any plaintiffs . . . ." Order,
Case No. 9:08-cv-80119 (S.D. Fla. 2008), [DE 238] at 4-5 (emphasis added); see also Order,
Case No. 9:08-cv-80893, [DE 193] at 2 (emphasis added).
Edwards Files Civil Suits Against Epstein
44. Edwards had a good faith belief that his clients felt angry and betrayed by the
criminal system and wished to prosecute and punish Epstein for his crimes against them in
whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane
Doe, Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual
assault of Jane Doe. See Edwards Affidavit, "N" at 17. Included in this complaint was a RICO
count that explained how Epstein ran a criminal conspiracy to procure young girls for him to
sexually abuse. See Complaint, Jane Doe v. Epstein (Exhibit "T").
45. On September 11, 2008, at the request of his client E.W., Brad Edwards filed a civil
suit against Jeffrey Epstein to recover damages for his sexual assault of E.W. See Complaint,
E.W. v. Epstein (Exhibit "U").
18
46. On September 11, 2008, at the request of his client L.M.., Brad Edwards filed a civil
suit against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint,
L.M. v. Epstein, (Exhibit "V").
47. Jane Doe's federal complaint indicated that she sought damages of more than
$50,000,000. Listing the amount of damages sought in the complaint was in accord with other
civil suits that were filed against Epstein (before any lawsuit filed by Edwards). See Complaint,
Jane Doe #4 v. Epstein (Exhibit "W") (filed by Herman and Mermelstein, PA).
48. At about the same time as Edwards filed his three lawsuits against Epstein, other
civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14,
2008 another law firm, Herman and Mellnelstein, filed the first civil action against Epstein on
behalf of one of its seven clients who were molested by Epstein. The complaints that attorney
Herman filed on behalf of his seven clients were similar in tenor and tone to the complaint that
Edwards filed on behalf of his three clients. See id.
49. Over the next year and a half, more than 20 other similar civil actions were filed by
various attorneys against Epstein alleging sexual assault of minor girls. These complaints were
also similar in tenor and tone to the complaint that Edwards filed on behalf of his clients. These
complaints are all public record and have not been attached, but are available in this Court's files
and the files of the U.S. District Court for the Southern District of Florida.
50. In addition to the complaints filed against Epstein in Florida, a female in New York,
Ava Cordero, filed a lawsuit against Epstein in New York making similar allegations - that
Epstein paid her for a massage then forced her to give him oral sex and molested her in other
ways when she was only 16 years old. Cordero was born a male, and in her complaint she
19
alleges that Epstein told her during the "massage", "I love how young you are. You have a tight
butt like a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York
Post, October 17, 2007, by Dareh Gregorian, link at:
http://www.nypost.com/p/news/regional/i ... OUtKYGPbPj se s si onid=6CA3
EBF1BEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as Exhibit "X".
51. Edwards's three complaints against Epstein contained less detail about sexual
abuse than (as one example) a complaint filed by attorney Robert Josephsberg from the law firm
of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). As recounted in
detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her
and lured her to Epstein's house. Maxwell and Epstein forced her to have sex with both of them
and within weeks Maxwell and Epstein were flying her all over the world. According to the
Complaint, Jane Doe 102 was forced to live as one of Epstein's underage sex slaves for years
and was forced to have sex with not only Maxwell and Epstein but also other politicians,
businessmen, royalty, academicians, etc. She was even made to watch Epstein have sex with
three 12-year-old French girls that were sent to him for his birthday by a French citizen that is a
friend of Epstein's. Luckily, Jane Doe 102 escaped to Australia to get away from Epstein and
Maxwell's sexual abuse.
52. Edwards learned that in addition to civil suits that were filed in court against
Epstein, at around the same time other attorneys engaged in pre-filing settlement discussions
with Epstein. Rather than face filed civil suits in these cases, Epstein paid money settlements to
more than 15 other women who had sexually abused while they were minors. See articles
regarding settlements attached hereto as Composite Exhibit "Y."
20

[admin]

HOUSE_OVERSIGHT_010566
txt
Cont'd.

Epstein's Obstruction of Normal Discovery and Attacks on His Victims
53. Once Edwards filed his civil complaints for his three clients, he began the normal
process of discovery for cases such as these. He sent standard discovery requests to Epstein
about his sexual abuse of the minor girls, including requests for admissions, request for
production, and interrogatories. See Edwards Affidavit, Exhibit "N", at Till 1-19 and 25.
Rather than answer any substantive questions about his sexual abuse and his conspiracy for
procuring minor girls for him to abuse, Epstein invoked his 5th amendment right against self-
incrimination. An example of Epstein's refusal to answer is attached as Composite Exhibit "Z"
(original discovery propounded to Epstein and his responses invoking 5th amendment).
54. During the discovery phase of the civil cases filed against Epstein, Epstein's
deposition was taken at least five times. During all of those depositions, Epstein refused to
answer any substantive questions about his sexual abuse of minor girls. See, e.g., Deposition
Attachments 1, 6 and 7.
55. During these depositions, Epstein further attempted to obstruct legitimate
questioning by inserting a variety of irrelevant infatuation about his case. As one of
innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's
2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that
question, as I would like to answer mostly every question you've asked me here today; however,
upon advice of counsel, I cannot answer that question. They've advised me I must assert my
Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse
me, against--under the Constitution. And though your partner, Jeffrey Heiman, was disbarred
after filing this lawsuit [a statement that was untrue], Mr. Edwards' partner sits in jail for
21
fabricating cases of a sexual nature fleecing unsuspecting Florida investors and others out of
millions of dollars for cases of a sexual nature with--I'd like to answer your questions; however if
I--I'm told that if I do so, I risk losing my counsel's representation; therefore I must accept their
advice." Epstein deposition, March 8, 2010, at 106 (Deposition attachment #10).
56. When Edwards had the opportunity to take Epstein's deposition, he only asked
reasonable questions, all of which related to the merits of the cases against Epstein. All
depositions of Epstein in which Mr. Edwards participated on behalf of his clients are attached to
this motion. See Edwards Affidavit, Exhibit "N" at 111 and Deposition attachments #1, 6, 7, 10,
11, 12, and 13. Cf. with Deposition of Epstein taken by an attorney representing BB (one in
which Edwards was not participating), https://www.youtube.com/watch?v=V-dqoEyYXx4; and
https://www.youtube.com/watch?v=YCNiY1tW-r0
57. Edwards's efforts to obtain infoimation about Epstein's organization for
procuring young girls was also blocked because Epstein's co-conspirators took the Fifth.
Deposition of Sarah Kellen, March 24, 2010 (hereinafter "Kellen Depo.") (Deposition
attachment #14); Deposition of Nadia Marcinkova, April 13, 2010, (Deposition attachment #9);
Deposition of Adriana Mucinska Ross, March 15, 2010 (hereinafter "Ross Depo.") (Deposition
attachment #15). Each of these co-conspirators invoked their respective rights against self-
incrimination as to all relevant questions, and the depositions have been attached.
58. At all relevant times Edwards has had a good faith basis to believe and did in fact
believe Sarah Kellen was an employee of Epstein's and had been identified as a defendant in at
least one of the complaints against Epstein for her role in bringing girls to Epstein's mansion to
be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on
22
all substantive questions regarding her role in arranging for minor girls to come to Epstein's
mansion to be sexually abused. Reinhart had previously been an Assistant United States
Attorney in the U.S. Attorney's Office for the Southern District of Florida when Epstein was
being investigated criminally by Reinhart's office. Reinhart left the United States Attorney's
Office and was immediately hired by Epstein to represent Epstein's pilots and certain co-
conspirators during the civil cases against Epstein. See Edwards Affidavit, Exhibit "N" at ¶11.
59. Edwards also had other lines of legitimate discovery blocked through the efforts
of Epstein and others. For example, Edwards learned through deposition that Ghislaine Maxwell
was involved in managing Epstein's affairs and companies. See deposition of Epstein's house
manager Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment
#16); See deposition of Epstein's housekeeper Louella Rabuyo, October 20, 2009, page 9, lines
17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene Morrison,
October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo
Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince
Andrew's Friend, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story,
September 23, 2007 by Wendy Leigh, link at
http://www.redicecreations.com/article. ... 18950HANNA SJOBERG. Exhibit "AA".
60. Alfredo Rodriguez testified that Maxwell took photos of girls without the girls'
knowledge, kept the images on her computer, knew the names of the underage girls and their
respective phone numbers and other underage victims were molested by Epstein and Maxwell
together. See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236.
23
61. In reasonable reliance on this and other infoimation, Edwards served Maxwell for
deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented
by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her
attorney was paid for (directly or indirectly) by Epstein. She was reluctant to give her
deposition, and Edwards tried to work with her attorney to take her deposition on teims that
would be acceptable to both sides. The result was the attached confidentiality agreement, under
which Maxwell agreed to drop any objections to the deposition, attached hereto as Exhibit "CC."
Maxwell, however, contrived to avoid the deposition. On June 29, 2010, one day before
Edwards was to fly to NY to take Maxwell's deposition, her attorney informed Edwards that
Maxwell's mother was deathly ill and Maxwell was consequently flying to England with no
intention of returning to the United States. Despite that assertion, Ghislaine Maxwell was in fact
in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton (former
President Clinton's daughter) and was captured in a photograph taken for OK magazine. Photos
from Issue 809 of the publication See US Weekly dated August 16, 2010 are attached hereto as
Exhibit "DD" and Edwards Affidavit, Exhibit "N" at ¶12.
62. Maxwell is not the only important witness to lie to avoid deposition by Edwards.
Upon review of the message pads that were taken from Epstein's home in the police trash pulls,
see Exhibit "J" supra, many were from Jean Luc Brunel, a French citizen and one of Epstein's
closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to
teach you how to speak Russian. She is 2x8 years old, not blonde. Lessons are free and you can
have your 1st today if you call." See Messages taken from Jean Luc Brunel are attached hereto as
Exhibit "EE." In light of these circumstances of the case, this message reasonably suggested to
24
Edwards that Brunel might have been procuring two eight-year-old girls for Epstein to sexually
abuse. According to widely circulated press reports reviewed by Edwards, Brunel is in his
sixties and has a reputation throughout the world (and especially in the modeling industry) as a
cocaine addict that has for years molested children through modeling agencies while acting as
their agent — conduct that has been the subject of critical reports, books, several news articles,
and a 60 Minutes documentary on Brunel's sexual exploitation of underage models. See
http://bradmillershero.blogspot.com/201 ... jects.html, attached hereto as Exhibit
63. Edwards learned that Brunel is also someone that visited Epstein on
approximately 67 occasions while Epstein was in jail. See Epstein's jail visitor log attached as
Exhibit "GG."
64. Edwards learned that Brunel currently runs the modeling agency MC2, a company
for which Epstein provides financial support. See Message Pad's attached as Exhibit "J" supra
and Sworn Statement of MC2 employee Maritza Vasquez, June 15, 2010, "Maritza Vasquez
Sworn Statement" attached at Exhibit "HH" at 1-16.
65. Employees of MC2 told Edwards that Epstein's numerous condos at 301 East 66
Street in New York were used to house young models. Edwards was told that MC2 modeling
agency, affiliated with Epstein and Brunel brought underage girls from all over the world,
promising them modeling contracts. Epstein and Brunel would then obtain a visa for these girls,
then would charge the underage girls rent, presumably to live as underage prostitutes in the
condos. See Maritza Vasquez Sworn Statement, Exhibit "HH" at 7-10, 12-15, 29-30, 39-41, 59-
60 and 62-67.
25
66. In view of this information suggesting Brunel could provide significant evidence
of Epstein's trafficking in young girls for sexual abuse, Edwards had Brunel served in New York
for deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "II."
Before the deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach)
contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in
January 2009 that Brunel had left the country and was back in France with no plans to return.
This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See
Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from
Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that
relevant period of time attached Exhibit "JJ". As a result, Edwards filed a Motion for Contempt,
attached hereto as Exhibit "KK" (Because Epstein settled this case, the motion was never ruled
upon.)
67. Edwards was also informed that Epstein paid for not only Brunel's representation
during the civil process but also paid for legal representation for Sarah Kellen (Epstein's
executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal
pilot), Dave Rogers (Epstein's personal pilot), Larry Harrison (Epstein's personal pilot), Louella
Rabuyo (Epstein's housekeeper), Nadia Marcinkova (Epstein's live-in sex slave), Ghislaine
Maxwell (manager of Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and
Janusz Banasiak (Epstein's house manager) It was nearly impossible to take a deposition of
someone that would have helpful information that was not represented by an attorney paid for by
Epstein. See Edwards Affidavit, Exhibit "N" at ¶11.
26
68. While Epstein and others were preventing any legitimate discovery into his sexual
abuse of minor girls, at the same time he was engaging (through his attorneys) in brutal
questioning of the girls who had filed civil suits against him, questioning so savage that it made
local headlines. See Jane Musgrave, Victims Seeking Sex offender's Millions See Painful Pasts
Used Against Them, Palm Beach Post News, Jan. 23, 2010, available at
hap ://www.palmbeachpost. com/news/crime/vi ctims-s eeking-s ex-offenders-millions-see-painful-
pasts-192988.html attached hereto as Exhibit "LL."
Edwards Pursues Other Lines of Discovery
69. Because of Epstein's thwarting of discovery and attacks on Edwards's clients,
Edwards was forced to pursue other avenues of discovery. Edwards only pursued legitimate
discovery designed to further the cases filed against Epstein. See Edwards Affidavit, Exhibit
"N" at 1-111.
70. Edwards notified Epstein's attorneys of his intent to take Bill Clinton's deposition.
Edwards possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine
Maxwell who was Epstein's longtime companion and helped to run Epstein's companies, kept
images of naked underage children on her computer, helped to recruit underage children for
Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and
photographed underage females in sexually explicit poses and kept child pornography on her
computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein's private
plane to Africa and the news articles classified Clinton as Epstein's friend. (c) the complaint
filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be
sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty,
27
politicians, academicians, businessmen, and/or other professional and personal acquaintances" —
categories Clinton and acquaintances of Clinton fall into. The flight logs showed Clinton
traveling on Epstein's plane on numerous occasions between 2002 and 2005. See Flight logs
attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine
Maxwell, Sarah Kellen, and Adriana Mucinska, - all employees and/or co-conspirators of
Epstein's that were closely connected to Epstein's child exploitation and sexual abuse. The
documents clearly show that Clinton frequently flew with Epstein aboard his plane, then
suddenly stopped - raising the suspicion that the friendship abruptly ,ended, perhaps because of
events related to Epstein's sexual abuse of children. Epstein's personal phone directory from his
computer contains e-mail addresses for Clinton along with 21 phone numbers for him, including
those for his assistant (Doug Band), his schedulers, and what appear to be Clinton's personal
numbers. This information certainly leads one to believe that Clinton might well be a source of
relevant information and efforts to obtain discovery from him were reasonably calculated to lead
to admissible evidence. See Exhibits "B", "F" "AA", "DD", and "MM" and Edwards Affidavit,
Exhibit "N" at ¶15.
71. Bradley J. Edwards, Esq., provided notice that he intended to take the deposition
of Donald Trump. Edwards possessed a legitimate basis for doing so: (a) The message pads
confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach
mansion on several occasions during the time period most relevant to my Edwards's clients'
complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "I've known
Jeff for fifteen years. Terrific guy," "He's a lot of fun to be with. It is even said that he likes
beautiful women as much as I do, and many of them are on the younger side. No doubt about it --
28
Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals
with a passel of Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited,
socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin
Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder
who he is. By Landon Thomas Jr. (See article attached hereto as Exhibit "NN") (c) Trump
allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein sexually
assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe
102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be
Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified
that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged
was used to have sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach;
(g) Epstein's phone directory from his computer contains 14 phone numbers for Donald Trump,
including emergency numbers, car numbers, and numbers to Trump's security guard and
houseman. Based on this information, Edwards reasonably believed that Trump might have
relevant information to provide in the cases against Jeffrey Epstein and accordingly provided
notice of a possible deposition. See deposition of Mark Epstein, September 21, 2009, at 48-50
(Deposition Attachment #19); See Jane Doe 102 v. Epstein, Exhibit "B"; Exhibit "F";
"Exhibit"J"; "N" and See Edwards Affidavit, Exhibit "N" at ¶13.
72. Edwards provided notice that he intended to depose Alan Dershowitz. Edwards
possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with
Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th
book... The only person outside of my immediate family that I send drafts to is Jeffrey" The
29
Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See
article attached as Exhibit "00"); (c) Epstein's housekeeper Alfredo Rodriguez testified that
Dershowitz stayed at Epstein's house during the years when Epstein was assaulting minor
females on a daily basis; (d) Rodriguez testified that Dershowitz was at Epstein's house at times
when underage females where there being molested by Epstein (see Alfredo Rodriguez
deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly assisted in attempting to
persuade the Palm Beach State Attorney's Office that because the underage females alleged to
have been victims of Epstein's abuse lacked credibility and could not be believed that they were
at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house;
(f) Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only
Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians,
businessmen, and/or other professional and personal acquaintances" — categories that Dershowitz
and acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was
on Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot
and information (described above) suggested that sexual assaults may have taken place on the
plane; (h) Epstein donated $30 Million one year to the university at which Dershowitz teaches.
Based on this infoli__iation, Edwards had a reasonable basis to believe that Dershowitz might
have relevant information to provide in the cases against Jeffrey Epstein and accordingly
provided notice of a possible deposition. See Dershowitz letters to the State Attorney's office
attached as Exhibit "PP"; Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit
"MM"; Exhibits "B" and "00"; and Edwards Affidavit, Exhibit "N" at ¶14.
30
73. Epstein's complaint alleges that Edwards provided notice that he wished to take
the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by
the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N"
at ¶16.
74. Edwards gave notice that he intended to take David Copperfield's deposition.
Edwards possessed a legitimate basis for doing so. Epstein's housekeeper and one of the only
witnesses who did not appear for deposition with an Epstein bought attorney, Alfredo Rodriguez,
testified that David Copperfield was a guest at Epstein's house on several occasions. His name
also appears frequently in the message pads confiscated from Epstein's house. It has been
publicly reported that Copperfield himself has had allegations of sexual misconduct made against
him by women claiming he sexually abused them, and one of Epstein's sexual assault victims
also alleged that Copperfield had touched her in an improper sexual way while she was at
Epstein's house. Mr. Copperfield likely has relevant information and deposition was reasonably
calculated to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at
¶17.
75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible
witness. Richardson was properly identified as a possible witness because Epstein's personal
pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch. There was
information indicating that Epstein had young girls at his ranch which, given the circumstances
of the case, raised the reasonable inference he was sexually abusing these girls as he had abused
girls in West Palm Beach and elsewhere. Richardson had also returned campaign donations that
were given to him by Epstein, indicating that he believed that there was something about Epstein
31
with which he did not want to be associated. Richardson was not called to testify nor was he ever
subpoenaed to testify. See Edwards Affidavit, Exhibit "N" at ¶18.
76. Edwards learned of allegations that Epstein engaged in sexual abuse of minors on
his private aircraft. See Jane Doe 102 Complaint, Exhibit "B." Accordingly, Edwards pursued
discovery to confirm these allegations.
77. Discovery of the pilot and flight logs was proper in the cases brought by Edwards
against Epstein. Jane Doe filed a federal RICO claim against Epstein that was an active claim
through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal
enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed
the RICO claim at some point in the federal litigation, the legal team representing
Edwards' clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects
mentioned in the RICO claim remained relevant to other aspects of Jane Doe's claims against
Epstein, including in particular her claim for punitive damages. See Edwards Affidavit, Exhibit
"N" at ¶19.
78. Discovery of the pilot and flight logs was also proper in the cases brought by
Edwards against Epstein because of the need to obtain evidence of a federal nexus. Edwards's
client Jane Doe was proceeding to trial on a federal claim under 18 U.S.C. § 2255. Section 2255
is a federal statute which (unlike relevant state statutes) established a minimum level of recovery
for victims of the violation of its provisions. Proceeding under the statute, however, required a
"federal nexus" to the sexual assaults. Jane Doe had two grounds on which to argue that such a
nexus existed to her abuse by Epstein: first, his use of telephone to arrange for girls to be abused;
and, second, his travel on planes in interstate commerce. During the course of the litigation,
32
Edwards anticipated that Epstein would argue that Jane Doe's proof of the federal nexus was
inadequate. These fears were realized when Epstein filed a summary judgment motion raising
this argument. In response, the other attorneys and Edwards representing Jane Doe used the
flight log evidence to respond to Epstein's summary judgment motion, explaining that the flight
logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating
his sexual assaults. Because Epstein chose to settle the case before trial, Judge Marra did not
rule on the summary judgment motion.
79. Edwards had further reason to believe and did in fact believe that the pilot and
flight logs might contain relevant evidence for the cases against Epstein. Jane Doe No. 102's
complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as young as
12 years old and alleged that Epstein's plane was used to transport underage females to be
sexually abused by him and his friends. The flight logs accordingly were a potential source of
information about either additional girls who were victims of Epstein's abuse or friends of
Epstein who may have witnessed or even participated in the abuse. Based on this
information, Edwards reasonably pursued the flight logs in discovery.
80. In the fall of 2009, Epstein gave a recorded interview to George Rush, a reporter
with the New York Daily News about pending legal proceedings. In that interview, Epstein
demonstrated an utter lack of remorse for his crimes (but indirectly admitted his crimes) by
stating:
• People do not like it when people make good and that was one reason he (Epstein)
was being targeted by civil suits filed by young girls in Florida;
• He (Epstein) had done nothing wrong;
33
• He (Epstein) had gone to jail in Florida for soliciting prostitution for no reason;
• If the same thing (i.e., sexual abuse of minor girls) had happened in New York, he
(Epstein) would have received only a $200 fine;
• Bradley J. Edwards was the one causing all of Epstein's problems (i.e., the civil
suits brought by Jane Doe and other girls);
• L.M. came to him as a prostitute and a drug user (i.e., came to Epstein for sex,
rather than Epstein pursuing her);
• All the girls suing him are only trying to get a meal ticket;
• The only thing he might have done wrong was to maybe cross the line a little too
closely;
• He (Epstein) was very upset that Edwards had subpoenaed Ghisline Maxwell, that
she was a good person that did nothing wrong (i.e., had done nothing wrong even
though she helped procure young girls to satisfy Epstein's sexual desires);
• With regard to Jane Doe 102 v. Epstein, which involved an allegation that Epstein
had repeatedly sexually abused a 15-year-old girl, forced her to have sex with his
friends, and flew her on his private plane nationally and internationally for the
purposes of sexually molesting and abusing her, he (Epstein) flippantly said that
the case was dismissed, indicating that the allegations were ridiculous and untrue.
See Affidavit of Michael J. Fisten attached hereto as Exhibit "QQ."
81. The Rush interview also demonstrated perjury (a federal crime) on the part of
Epstein. Epstein lied about not knowing George Rush. See Epstein Deposition, February 17,
2010, taken in L.M. v. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155
line 9, (Deposition attachment #7), wherein Jeffrey Epstein clearly impresses that he does not
recognize George Rush from the New York Daily News. This impression was given despite the
fact that he gave a lengthy personal interview about details of the case that was tape recorded
with George Rush.
34
Epstein 's Harassment of Witnesses Against Him
82. At all relevant times Edwards has a good faith basis to believe and did in fact
believe that Epstein engaged in threatening witnesses. See Incident Report, Exhibit "A" at p. 82,
U.S. Attorney's Correspondence, Exhibit "C" - Indictments drafted by Federal Government
against Epstein; and Edwards Affidavit, Exhibit "N" at ¶11.
83. Despite three no contact orders entered against Epstein (see Exhibit C, supra),
Edwards learned that Epstein continued to harass his victims. For example, Jane Doe had a trial
set for her civil case against him on July 19, 2010. As that trial date approached, defendant
Epstein intimidated her in violation of the judicial no-contact orders. On July 1, 2010, he had a
"private investigator" tail Jane Doe — following her every move, stopping when she stopped,
driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove
to her home, the "private investigator" then parked in his car approximately 25 feet from Jane
Doe house and flashed his high beam lights intermittently into the home. Even more
threateningly, at about 10:30 p.m., when Jane Doe fled her home in the company of a retired
police officer employed by Jane Doe's counsel, the "private investigator" attempted to follow
Jane Doe despite a request not to do so. The retired officer successfully took evasive action and
placed Jane Doe in a secure, undisclosed location that night. Other harassing actions against
Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein
detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit "RR."
Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children
84. The civil cases Edwards filed against Epstein on behalf of L.M., E.W., and Jane
Doe were reasonably perceived by Edwards to be very strong cases. Because Epstein had
35
sexually assaulted these girls, he had committed several serious torts against them and would be
liable to them for appropriate damages. See Preceding Undisputed Facts. Because of the
outrageousness of Epstein's sexual abuse of minor girls, Edwards reasonably expected that
Epstein would also be liable for punitive damages to the girls. Because Edwards could show that
Epstein had molested children for years and designed a complex premeditated scheme to procure
different minors everyday to satisfy his addiction to sex with minors, the punitive damages
would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for
years. Epstein was and is a billionaire. See Complaint, ¶49 (referring to "Palm Beach
Billionaire"); see also Epstein Deposition, February 17, 2010, at 172-176 (Deposition
Attachment #7) (taking the Fifth when asked whether he is a billionaire). Accordingly, Edwards
reasonably believed the punitive damages that would have to be awarded against Epstein would
have been substantial enough to punish him severely enough for his past conduct as well as deter
him from repeating his offenses in the future. See Edwards Affidavit, Exhibit "N" at ¶19.
85. On July 6, 2010, rather than face trial for the civil suits that had been filed against
him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases against him. The terms of
the settlement are confidential. The settlement amounts are highly probative in the instant action
as Epstein bases his claims that Edwards was involved in the Ponzi scheme on Epstein's inability
to settle the L.M., E.W., and Jane Doe cases for "minimal value". His continued inability to
settle the claims for "minimal value" after the Ponzi scheme was uncovered would be highly
probative in discrediting any causal relationship between the Ponzi scheme and Edwards's
settlement negotiations. See Edwards Affidavit, Exhibit "N" at ¶21.
Edwards Non-Involvement in Fraud by Scott Rothstein
36
86. From in or about 2005, through in or about November 2009, Scott Rothstein
appears to have run a giant Ponzi scheme at his law firm of Rothstein, Rosenfeldt and Adler PA.
("RRA"). This Ponzi scheme involved Rothstein falsely informing investors that settlement
agreements had been reached with putative defendants based upon claims of sexual harassment
and/or whistle-blower actions. Rothstein falsely informed the investors that the potential
settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott
W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit "SS."
87. It has been alleged that among other cases that Rothstein used to lure investors
into his Ponzi scheme were the cases against Epstein that were being handled by Bradley J.
Edwards, Esq. Edwards had no knowledge of the fraud or any such use of the Epstein cases. See
Edwards Affidavit, Exhibit "N" at ¶9.
88. Bradley J. Edwards, Esq., joined RRA in about April 2009 and left RRA in
November 2009 — a period of less than one year. Edwards would not have joined RRA had he
been aware that Scott Rothstein was running a giant Ponzi scheme at the fitat. Edwards left
RRA shortly after learning of Rothstein's fraudulent scheme. Id. at ¶8.
89. At no time prior to the public disclosure of Rothstein's Ponzi scheme did Edwards
know or have reason to believe that Rothstein was using legitimate claims that Edwards was
prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose. Id. at ¶20.
90. Edwards never substantively discussed the merits of any of his three cases against
Epstein with Rothstein. See Deposition of Bradley J. Edwards taken March 23, 2010, at 110-16.
(hereinafter "Edwards Depo") (Deposition Attachment #22).
37
91. On July 20, 2010, Bradley Edwards received a letter from the U.S. Attorney's
Office for the Southern District of Florida — the office responsible for prosecuting Rothstein's
Ponzi scheme. The letter indicated that law enforcement agencies had determined that Edwards
was "a victim (or potential victim)" of Scott Rothstein's federal crimes. The letter informed
Edwards of his rights as a victim of Rothstein's fraud and promised to keep Edwards informed
about subsequent developments in Rothstein's prosecution. See Letter attached hereto as Exhibit
92. Jeffrey Epstein filed a complaint with the Florida Bar against Bradley Edwards,
Esq., raising allegations that Edwards and others were involved in the wrongdoing of Scott
Rothstein. After investigating the claim, the Florida Bar dismissed this complaint. See Edwards
Affidavit, Exhibit "N" at ¶23.
Epstein Takes the Fifth When Asked Substantive Questions About His Claims Against Edwards
93. On March 17, 2010, defendant Epstein was deposed about his lawsuit against
Edwards. Rather than answer substantive questions about his lawsuit, Epstein repeatedly
invoked his Fifth Amendment privilege. See Epstein Depo. taken 3/17/10, Deposition
Attachment #1.
94. In his deposition, Epstein took the Fifth rather than answer the question:
"Specifically what are the allegations against you which you contend Mr. Edwards ginned up?"
Id. at 34.
95. In his deposition, Epstein took the Fifth rather than name people in California that
Edwards had tried to depose to increase the settlement value of the civil suit he was handling. Id.
at 37.
38
96. In his deposition, Epstein took the Fifth rather than answer the question: "Do you
know former President Clinton personally." Id.
97. In his deposition, Epstein took the Fifth rather than answer the question: "Are you
now telling us that there were claims against you that were fabricated by Mr. Edwards?" Id. at
39.
98. In his deposition, Epstein took the Fifth rather than answer the question, "Well,
which of Mr. Edwards' cases do you contend were fabricated." Id.
99. In his deposition, Epstein took the Fifth rather than answer the question: "What is
the actual value that you contend the claim of E.W. against you has?" Id. at 45.
100. In his deposition, Epstein took the Fifth rather than answer a question about the
actual value of the claim of L.M. and Jane Doe against him. Id.
101. In his deposition, taken prior to the settlement of Edwards's clients claims against
Epstein, Epstein took the Fifth rather than answer the question: "Is there any pending claim
against you which you contend is fabricated?" Id. at 71.
102. In his deposition, Epstein took the Fifth rather than answer the question: "Did you
ever have damaging evidence in your garbage?" Id. at 74.
103. In his deposition, Epstein took the Fifth rather than answer the question: "Did
sexual assaults ever take place on a private airplane on which you were a passenger?" Id. at 88.
104. In his deposition, Epstein took the Fifth rather than answer the question: "Does a
flight log kept for a private jet used by you contain the names of celebrities, dignitaries or
international figures?" Id. at 89.
39
105. In his deposition, Epstein took the Fifth rather than answer the question: "Have
you ever socialized with Donald Trump in the presence of females under the age of 18?" Id. at
89.
106. In his deposition, Epstein took the Fifth rather than answer the question: "Have
you ever socialized with Alan Dershowitz in the presence of females under the age of 18." Id. at
90.
107. In his deposition, Epstein took the Fifth rather than answer the question: "Have
you ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id. at 91-
92.
108. In his deposition, Epstein took the Fifth rather than answer the question: "Did you
ever socialize with David Copperfield in the presence of females under the age of 18?" Id. at
109. In his deposition, Epstein took the Fifth rather than answer the question: "Have
you ever socialized with Mr. Richardson [Governor of New Mexico and foimerly U.S.
Representative and Ambassador to the United Nations] in the presence of females under the age
of 18." Id. at 94.
110. In his deposition, Epstein took the Fifth rather than answer the question: "Have
you ever sexually abused children?" Id. at 95.
111. In his deposition, Epstein took the Fifth rather than answer the question: "Did you
have staff members that assisted you in scheduling appointments with underage females; that is,
females under the age of 18." Id. at 97-98.
112. In his deposition, Epstein took the Fifth rather than answer the question: "On how
many occasions did you solicit prostitution." Id. at 102.
40
113. In his deposition, Epstein took the Fifth rather than answer the question: "How
many minors have you procured for prostitution?" Id. at 104.
114. In his deposition, Epstein took the Fifth rather than answer the question: "Have
you ever coerced, induced or enticed any minor to engage in any sexual act with you?" Id. at
107.
115. In his deposition, Epstein took the Fifth rather than answer the question: "How
many times have you engaged in fondling underage females?" Id. at 108.
116. In his deposition, Epstein took the Fifth rather than answer the question: "How
many times have you engaged in oral sex with females under the age of 18?" Id. at 110.
117. In his deposition, Epstein took the Fifth rather than answer the question: "Do you
have a personal sexual preference for children?" Id. at 111-12.
118. In his deposition, Epstein took the Fifth rather than answer the question: "Your
Complaint at page 27, paragraph 49, says that `RRA and the litigation team took an emotionally
driven set of facts involving alleged innocent, unsuspecting, underage females and a Palm Beach
billionaire, and sought to turn it into a goldmine,' end of quote. Who is the Palm Beach
billionaire referred to in that sentence?" Id. at 112-13.
119. In his deposition, Epstein took the Fifth rather than answer the question: "Who are
the people who are authorized to make payment [to your lawyers] on your behalf?" Id. at 120.
120. In his deposition, Epstein took the Fifth rather than answer the question: "Is there
anything in L.M.'s Complaint that was filed against you in September of 2008 which you
contend to be false?" Id. at 128.
41
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November_____ 2010 a copy of the foregoing has been
served via Fax and U.S. Mail to all those on the attached service list.
By:
Jack Scarola
Searcy, Denney, Scarola, Barnhart & Shipley
2139 Palm Beach Lakes Blvd
West Palm Beach, FL 33409
(561) 686 10
(561 84-581 (fax)
JAC AROLA
Flo ar No.: 169440
42
SERVICE LIST
Christopher E. Knight, Esq.
Joseph L. Acketman, Esq.
FOWLER WHITE BURNETT P.A.
901 Phillips Point West
777 South Flagler Drive
West Palm Beach, FL 33401
Jack Alan Goldberger, Esq.
Atterbury Goldberger et al.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401
Marc S. Nurik, Esq.
Law Offices of Marc S. Nurik
One E. Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Gary M. Farmer, Jr.
Farmer, Jaffe, Weissing,
Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
43