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TAB 1
HOUSE OVERSIGHT 012197
First Assistant U.S. Attorney
DELIVERY BY FACSIMILE
Jay P. Lefkowitz, Esq.
Kirkland & Ellis LLP
Citigroup Center
153 East 53rd Street •
New York, New York 10022-4675
Re: Jeffrey Epstein
U.S. Department of Justice
United States Attorney
Southern District of Florida
99 PIE. 4 Street
Miami, FL 33132
(305) 961-9100
May 19, 2008
Dear Mr. Lefkowitz,
I am in receipt of your e-mail dated May 19, 2008 to the United States Attorney. The U.S.
Attorney would like me to advise you that all communications and inquiries related to the Epstein
matter, will be handled by AUSA Marie Villafana and/or her supervisor, Karen Atkinson, so he does
not intend to respond to your e-mail or calls unless AUSA Villafana and/or her supervisors advise
him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United
States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such
deadline. Should you decide to provide the SDFL with any additional information, please do so
through AUSA Villafana, and, in her absence, AUSA Atkinson.
On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt,
Esq. and Lilly Ann Sanchez, Esq., as well as numerous other nationally-renowned lawyers, including
but not limited to Harvard Law Professor Alan Dershowitz, former Independent Counsel and
Solicitor General of the United States Kenneth Starr, just to name a few, entered into a global
resolution of state and federal liabilities faced by your client ("the Agreement") with the SDFL.
Although you and other members of the defense team have since claimed that the Agreement was
the product of adhesion, the following facts demonstrate that Epstein knowingly and voluntarily
entered into the Agreement in order to avoid a federal indictment regarding his sexual conduct
involving minor victims. Despite the fact that by signing the Agreement, Epstein gave up the right
to object to its provisions, the SDFL bent over backwards to exhaustively consider and re-consider
your objections. Since these objections have finally been exhausted and Epstein has previously
expressed his intent to not comply with several of the terms and conditions of the Agreement as set
forth below, the SDFL hereby notifies you that unless he complies with all of the terms and
conditions of the Agreement, as modified by the United States Attorney's December 19,2007 letter
to Ms. Sanchez by close of business on Monday, June 2, 2008, the SDFL will elect to terminate the
Agreement.
HOUSE OVERSIGHT 012198
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 2 OF 6
Background
The Agreement was the product of months of negotiations. Specifically, you requested and
received numerous meetings, at the highest levels of the SDFL and DOJ's Child Exploitation and
Obscenity Section (CEOS) concerning claims that (a) the investigation merely produced evidence
of relatively innocuous sexual conduct with some minors who, unbeknownst to Epstein,
misrepresented their ages; (b) the authorities investigating Epstein engaged in misconduct; (c) the
contemplated federal statutes have no applicability to this matter; and (d) the federal authorities
disregarded the fundamental policy against federal intervention with state criminal proceedings.
After careful review, the SDFL ultimatelyrejected those claims. Subsequent to its decision, however,
but before proceeding any further, the SDFL provided you with 30 days to appeal the decision to the
Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an
appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the
execution of the Agreement.
The Negotiation Phase
During negotiations, you tried to avoid a resolution that called for incarceration and
registration as a sexual offender — both of which would be triggered by a successful federal
prosecution. The SDFL believed and continues to believe that should this matter proceed to trial,
your client would be convicted of the federal statutes identified in the Agreement. In order to achieve
a global resolution, the SDFL indicated a willingness to defer to the State the length of incarceration;
however, it remained adamant that Epstein register as a sex offender and that all victims identified
during the investigation remain eligible for compensation. In order to achieve this result, the parties
considered two alternatives, a plea to federal charges that limited Epstein's sentencing exposure, or,
as suggested by you, a plea to state charges encompassing Epstein's conduct. Ultimately, the parties
agreed to, inter alio, a plea to the state charges outlined in the Agreement, registration and a method
of compensation.
The Agreement
The crux of the Agreement defers in favor of the State federal prosecution of Epstein for his
sexual conduct involving those minor victims identified as of September 24, 2007, in exchange for
a guilty plea to a state . offense that requires registration as a sex offender; a sufficient term of
imprisonment; and a method of compensation for the victims such that they would be placed in the
same position as if Epstein had been convicted of one of the enumerated offenses set forth in Title
18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty
plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and
procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offense that requires
him to register as a sex offender); (2) a 30-month sentence including 18 months' incarceration in
county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry
HOUSE OVERSIGHT 012199
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 3 OF 6
of the guilty plea and sentence no later than October 26, 2007; and (5) the start of the above-
mentioned sentence no later than January 4, 2008.
Furthermore, and significantly, Epstein agreed that he had the burden of ensuring compliance
of the Agreement with the Palm Beach County State Attorney's Office and the Judge of the 15th
Judicial Circuit and "that the failure to do so will be a breach of the agreement" (emphasis added).
Post-Execution of the Agreement
Within weeks of the execution of the Agreement, you sought to delay the entry of Epstein's
guilty plea and sentence. After the SDFL agreed to accommodate your request, counsel for Epstein
began taking issue with the methodology of compensation, notification to the victims, and the issues
that had been previously considered and rejected during negotiations, i.e., that the conduct does not
require registration and the contemplated state and federal statutes have no applicability to the instant
matter.
A. Delay.
The Agreement required that "Epstein shall use his best efforts to enter his guilty plea and
be sentenced not later than October 26, 2007. The United States has no objection to Epstein self-
reporting to begin serving his sentence not later than January 4, 2008." Agreement, pages 4-5,
paragraph 11 (emphasis added). After the Agreement was executed, the SDFL accommodated your
request to extend the October 26th plea deadline to November 20th based upon, what seemed to be,
reasonable scheduling conflict issues.' By early November, you represented that the presiding state
courtjudge would not "stagger the plea and sentencing as contemplated in the Agreement."Although
the Agreement clearly did not contemplate a staggered "plea and sentencing," the SDFL again agreed
to accommodate Epstein's request to appear in state court for plea and sentencing on January 4,
2008.2
I "Accordingly, I have now confirmed with Mr. Epstein's Florida counsel that the state's
attorney's office and the court will be available to have him enter his plea on November 20. So we will
plan to proceed on one that date." October 18;2007 email from Jay Lefkowitz to USA R. Alexander
Acosta.
On the same day, Mr. Lefkowitz confirmed with First Assistant Jeffrey H. Sloman that this
postponement " will not affect when Epstein begins serving his sentence."
2 Correspondence from Jay Lefkowitz to FAUSA Sloman dated November 8, 2007 ("the judge
has invited the parties to appear for the plea and sentencing on January 41, we do not anticipate any delay
beyond that date.")
HOUSE OVERSIGHT 012200
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 4 OF 6
B. Method of Compensation and Notification.
During this same time period, you and others, including the former Solicitor General of the
United States Kenneth Starr, took issue with the implementation of the methodology of
compensation (hereinafter "the 2255 provision")3 and the SDFL's intention to notify the victims
under 18 U.S.C. Section 3771 (you objected to victims being notified of time and place of Epstein' s
state court sentencing hearing). In response, the SDFL offered, in my opinion, numerous and various
reasonable modifications and accommodations which ultimately resulted in United States Attorney
R. Alexander Acosta's December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United
States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to
address, let alone consider. He proposed the following language regarding the 2255 provision:
"Any person, who while a minor, was a victim of a violation of an offense enumerated in
Title 18, United States Code, Section 2255, will have the same rights to proceed under
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an
enumerated offense. For purposes of implementing this paragraph, the United States shall
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in
an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority
interpreting this provision, including any authority determining which evidentiary burdens
if any a plaintiff must meet, shall consider that it is the intent of the parties to place these
identified victims in the same position as they would have been had Mr. Epstein been
convicted at trial. No more; no less."
Regarding the issue of notice to the victims, USA Acosta proposed to notify them of the
federal resolution as required by law; however, IN* will defer to the discretion of the State
Attorney regarding whether he wishes to provide victims with notice of the state proceedings,
although we will provide him with the information necessary to do so if he wishes." As you know,
you rejected these proposals as well. See December 26, 2007 correspondence from Jay Lefkowitz
to USA Acosta.
3 Prior to any issues arising concerning the implementation of the 2255 provision, the SDFL
unilaterally agreed to assign its responsibility to select the attorney representative for the alleged victims
to an independent third-party. This was done to avoid even the appearance of favoritism in the selection
of the attorney representative. As a result, on October 29, 2007, the parties executed an Addendum
wherein it was mutually agreed that former United States District Court Judge Edward B. Davis would
serve as the independent third-party. Judge Davis selected the venerable law firm of Podhurst and
Josefsberg to represent the approximately 34 alleged identified victims.
HOUSE OVERSIGHT 012201
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 5 OF 6
C. "Mr. Epstein Does Not Believe He Is Guilty Of The Federal Charges Enumerated
Under Section 2255."
At our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for
Epstein announced, inter alia, that it was a "profound injustice" to require Epstein to register as a
sex offender and reiterated that no federal crime, especially 18 U.S.C. Section 2422(b), had been
committed since the statute is only violated if a telephone or means of interstate commerce is used
to do the persuading or inducing. This particular attack on this statute had been previously raised and
thoroughly considered and rejected by the SDFL and CEOS prior to the execution of the Agreement.
You also argued that the facts were inapplicable to the contemplated state statutes and that Epstein
should not have been allowed to have been induced into the Agreement because the facts were not
what he understood them to be. It should be noted that the SDFL has never provided you with any
evidence supporting its investigation. This is not, and has never been, an Alford plea situation (see
North Carolina v. Alford, 400 U.S. 25, 91 S.Ct. 160 (1970)). Ultimately, you requested an
independent review.
Subsequent to the above-mentioned meeting, the SDFL received three letters from you and/or
Mr. Starr which expanded on some of the themes announced in the December 14th meeting.
Essentially, you portrayed the SDFL as trying to coercea plea to unknown allegations and incoherent
theories. On December 17, 2007, you decreed that Epstein's conduct did not meet the requirements
•of solicitation of minors to engage in prostitution (Fl. Stat. Section 796.03) one of the enumerated
crimes Epstein had previously agreed to plead guilty to; that Epstein's conduct does not require
registration under Florida law; and the State Attorney's Office does not believe the conduct is
registrable. On December 21, 2007, you rejected the USA's proposed resolution of the 2255
provision because you "strongly believe that the provable conduct of Mr. Epstein with respect to
these individuals fails to satisfy the requisite elements of either 18 U.S.C. Section[s] 2422(b) ... or
2423(b)." In your December 26, 2007 correspondence you stated that "we have reiterated in
previous submissions that Mr. Epstein does not believe he is guilty of the federal charges enumerated
under section 2255" and requiring "Mr. Epstein to in essence admit guilt, though he believes he did
not commit the requisite offense."
As the SDFL has reiterated time and time again, it does not want, nor does it expect, Epstein
to plead guilty to a charge he does not believe he committed. As a result, we obliged your request
for an independent de novo review of the investigation and facilitated such a review at the highest
levels of the Department of Justice. It is our understanding that that independent review is now
complete and a determination has been made that there are no impediments to a federal prosecution
by the SDFL.
HOUSE OVERSIGHT 012202
JAY P. LEFKOWITZ, ESQ.
May 19, 2008
PAGE 6 OF 6
Conclusion
On February 25, 2008, I sent you an e-mail setting forth a timetable for moving forward in
the event that CEOS disagreed with your position. That time is now. As you know, my February 25th
email stated that I would give you one week to comply with the terms and conditions of the
Agreement, as modified by the USA's December 19th letter to Ms. Sanchez. In light of the upcoming
Memorial Day weekend, I have decided to extend that timetable to the close of business on Monday,
June 2, 2008, which is a full two weeks.
Sincerely,
R. Alexander Acosta
United States Attorney.
By:
Jeffrey H. Sloman
First Assistant United States Attorney
cc: R. Alexander Acosta
United States Attorney
A. Marie VilIafana
Assistant U.S. Attorney
Karen Atkinson .
Assistant U.S. Attorney
HOUSE OVERSIGHT 012203
TAB 2
HOUSE OVERSIGHT 012204
11/05/2007 11:26 FAX
11/05/07 MON 1005 FAX 305 330 6440 EXECUTIVE OFFICE
on /003
I'dj001
U.S. Department of Justice
United States Attorney
Southern District of Florida
UNITED STA.TE,S ATTORNEY'S OFFICE
SOUTHERN DISTRICT OF FLORIDA
99 NE 41-TH STREET
WAKE, FLORIDA 33132-2111
Jeffrey H. Slo ma n
First Assistant U.S. Attorney
305 961 9299
Cynciee Campos
Staff Assistant
305 961 9461
305 530-6444 fax
FACSIMILE TRANSMISSION
COVER SHEET
DATE: November 5, 2007
TO: Jay Lefkowitz, Esquire
FAX NUMBER: (212) 446 4900
SUBJECT: Jeffrey Epstein
NUMBER OF PAGES, INCLUDING THIS PAGE: 3
Message/Comments:
Inesiniiie contains PRIVFLEGIM 4ND CONFIDENTIAL INPORMA"I'ION intended only for thc LISC of the
A ddreswe(s) named Qbove. If you arc not the intended recipient of this caesimile, or the employee or agent respomsible
for delivering, it to the intended recipient, you are hereby notified that any clisttcrnination or coping of this faesimile is
strictly prohibited nyou ha vc received thiN facsimile Lit eTTOT, please immediately notify wi by telephone and return the
onal thesimileto os at the above address via the, U.S. POsial Service, Thank you,
HOUSE OVERSIGHT 012205
11/05/2007 11:27 FAX
11/05/07 MON 10:05 FAX 305 530 6440 EXECUTIVE OFFICE
U.S. Department of Justice
DELIVERY.ByFACSIMTI...E
Jay P. Lefkowitz, Esq.
Kirkland Lk,: Ellis
Citigroup Center
153 East 53r.l Street
New York, New York 10022-4675
Jeffry Epstei
Dear Jay:
United States Attorney
Southern District of Florida
991V.E. 4th Street
Miami, FL 33132-2111
(305) 961-9299
Far:sin:tie: (305) 530-6444
November 5, 2007
• • •
a 002/003
411002
Several things have come to my attention that seem contrary to your client intending to abide
by his obligations under the Non-Prosecution Agreement. As you know, that agreement requires our
Office to inform you of potential breaches to give you and your client the opportunity to respond
before an indictment is filed. At this time, I do not believe that the agreement has been breached;
however, I have sufficient concerns that need to be addressed.
First, I understand that private investigators working for Mr. Epstein have contacted victims
to ask them whether any detectives or FBI agents have discussed a financial settlement with them.
On one occasion, the private investigators told the parent of a victim that she should get an attorney
for her daughter and she should do so right away. These actions are troublesome because the FBI
agents legally are required to advise the victims of the resolution or the matter, which includes
informing them that, as part of the resolution, that Mr. Epstein has agreed to pay damages in some
circumstances. Furthermore, Mr. Epstein well knows that we are in the process of selecting an
attorney to represent the victims and, but for the inordinate amount of time spent negotiating the
Addendum, that attorney would already have been selected. Paragraph 7 of the Non-Prosecution
Agreement explicitly provides that contact with the victims shall be through that counsel.
Accordingly, please confirm that there will be no further efforts to contact any victims until Judge
Davis selects the attorney representative and that, thereafter, contact will be made only through that
counsel.
Second, the Non-Prosecution Agreement requires Mr. Epstein to use his best efforts to enter
his guilty plea and to be sentenced not later than October 26, 2007. Despite this obligation, the
Office agreed that Mr. Epstein could postpone this deadline to November, but reiterated that Mr.
HOUSE OVERSIGHT 012206
11/05/2007 11:27 FAX
11/05/07 MON 10:00 FAX 305 530 6440
EXECUTIVE OFFICE
el 003/003
VI nos
JAY P. IxpKowrinz, ESQ.
Nov2mt:IER 5, 2007
PACE 2 OF 2
Epstein had to begin his term of incarceration not later than January 4, 2008. I have learned that the
November hearing has been removed from the calendar and the next case disposition conference has
not been set until January 7, 2008. This delay is unacceptable, and, pursuant to your obligations, the
Office requests that you confer with the State Attorney's Office to try to find a date in November
when the judge is available to conduct a simultaneous plea and sentencing, if you cannot find such
a date, please provide documentation of your efforts to abide by the terms of the Non-Prosecution
Agreement.
Third, there have been several press reports that Mr. Epstein no longer intends to enter a
guilty plea. Normally I would not pay any attention to such reports, but your recent correspondence
attempting to restrict our office from communicating with the State .Attorney's Office and the
allusion to the imposition of sentences that clearly fall outside the terms of the Non-Prosecution
Agreernent raises concern. Please confirm that Mr. Epstein intends to abide by his agreement to
plead guilty to the specified charges and to make a binding recommendation that the Court impose
a sentence of 18 months of continuous confinement in the county jail.
Finally, the Non-Prosecution Agreement requires that you provide the Office with copies of
all proposed agreements with the State Attorney's Office before Mr. Epstein signs any such
agreements. To date, no such agreements have been received. Please provide me with copies of any
and all agreements with the State Attorney's Office for our review. The Office also would like to
have someone present at the change ofplea and sentencing to monitorMr, Epstein's compliance with
the terms of the Non-Prosecution Agreement, so please keep me informed of the date, time, and
location of the hearing.
Please provide me with a written response, adopted by Mr. Epstein, addressing these
concerns and reiterating Mr. Epstein's intention to comply with the tenns of the Non-Prosecution
Agreement by November 8, 2007.
By:
CO: R. Alexander Acosta, U.S. Attorney
AUSA A. Marie Villafalia
Jeffrey S ornan
Sincerely,
R. Alexander Acosta
United States A omey
First Assistant linited States Attorney
HOUSE OVERSIGHT 012207
TAB 3
HOUSE OVERSIGHT 012208
TOLL RECORDS OF SARAH KELLEN'S CALLS
• MR. EPSTEIN DID NOT KNOW WHO WOULD BE COMING TO GIVE HIM A MASSAGE.
(561) 635-
Wednesday, April 27, 2005 9:02AM 3454
(561) 801-
Wednesday, April 27, 2005 9:03AM 3590
(561) 714-
Wednesday, April 27, 2005 12:14PM 0546
(561) 714-
Wednesday, April 27, 2005 12:15PM 0546
(561) 309-
Wednesday, April 27, 2005 3:16PM 0079
(561) 309-
Wednesday, April 27, 2005 3:20PM 0079
(561) 644-
Thursday, May 05, 2005 3:28PM 3713
(561) 644-
Thursday, May 05, 2005 8:43PM 3713
(561) 644-
Thursday, May 05, 2005 8:48PM 3713
(561) 644-
Thursday, May 05, 2005 9:13PM 3713
(561) 644-
Thursday, May 05, 2005 10:03PM 3713
(561) 389-
Friday, May 06, 2005 8:30AM 6874
(561) 644-
Friday, May 06, 2005 8:59AM 3713
(561) 714-
Friday, May 06, 2005 9:33AM 0546
(561) 389-
Friday, May 06, 2005 9:34AM 6874
(561) 309-
Friday, May 06, 2005 9:35AM 0079
(561) 644-
Friday, May 06, 2005 10:58AM 3713
(561) 644-
Friday, May 06, 2005 5:35PM 3713
(561) 644-
Friday, May 06, 2005 7:50PM 3713
(561) 644-
Saturday, May 07, 2005 11:03AM 3713
(561) 389-
Saturday, May 07, 2005 11:04AM 6874
(561) 262-
Sunday, May 08, 2005 11:39AM 6186
(561) 684-
Sunday, May 08, 2005 12:28PM 6642
(561) 262-
Sunday, May 08, 2005 3:20PM 6186
(561) 262-
Sunday, May 08, 2005 3:21PM 6186
1 Mr. Rofrano is Mr. Epstein's chiropractor.
HOUSE OVERSIGHT 012209
• MR. EPSTEIN DID NOT TARGET ANY ONE PARTICULAR INDIVIDUAL, NOR DID HE TARGET MINORS.
ALL OF THE CALLS BELOW WERE MADE TO WOMEN OVER THE AGE OF 18.
(561) 389-
Saturday, July 02, 2005   9:50AM   6874   cell
(561) 635-
Saturday, July 02, 2005   11:33AM   3454   cell
(561) 856-
Saturday, July 02, 2005   11:54AM   2974   cell
(561) 635-
Saturday, July 02, 2005   12:03PM   3454   cell
(561) 324-
Saturday, July 02, 2005   1:49PM   7996   cell
(561) 324-
Saturday, July 02, 2005   3:21 PM   7996   cell
(561) 635-
Saturday, July 02, 2005   3:22PM   3454   cell
(561) 324-
Saturday, July 02, 2005   3:58PM   7996   cell
(561) 262-
Saturday, July 02, 2005   4:10PM   6186   cell
(561) 635-
Saturday, July 02, 2005   4:11 PM   3454   cell
(561) 302-
Saturday, July 02, 2005   6:20PM   1844   cell
(561) 389-
Saturday, July 02, 2005   9:25PM   6874   cell
(561) 324-
Sunday, July 03, 2005   1:14PM   7996   cell
(561) 574-
Sunday, July 03, 2005   1:44PM   0142   cell
(561) 262-
Sunday, July 03, 2005   9:57PM   6186   cell
(561) 714-
Sunday, September 18, 2005   9:58AM   0546   cell
(561) 324-
Sunday, September 18, 2005   9:59AM   7996   cell
(561) 635-
Sunday, September 18, 2005   9:59AM   3454   cell
(561) 801-
Sunday, September 18, 2005   10:02AM   3590   cell
(561) 662-
Sunday, September 18, 2005   10:04AM   3098   cell
(561) 302-
Sunday, September 18, 2005   10:44AM   1844   cell
(561) 389-
Sunday, September 18, 2005   1:10PM   6874   cell
(561) 389-
Sunday, September 18, 2005   4:10PM   6874   cell
(561) 324-
Sunday, September 18, 2005   5:17PM   7996   cell
(561) 714-
Sunday, September 18, 2005   9:36PM   0546   cell
(561) 714-
Sunday, September 18, 2005   9:45PM   0546   cell
HOUSE OVERSIGHT 012210
TAB 4
HOUSE OVERSIGHT 012211
6
7
8
9
10
11
12
13
14
16
17
18
19
20
21
22
23
1 MP: Detective Michele Pagan
2
3 KB: Kathy Back
4
5 MP: I_D. #8059, reference case number 05-368. The time now, by my watch, is
approximately 6 minutes past 2pm on 3/15/05. (Inaudible) High Ridge Family
Center, Sable Palm School.
UNK: Just High Ridge Family Center.
MP: Okay, the High Ridge Family Center. Present also is. could you state your name
please?
MP: Spell your name please?
MP: And your date of birth?
MP: And you are?
CB: Cathy Back, Family Therapist.
MP: Could you spell your name please?
KB: K-A-T-H-Y B-A-C-K.
MP: And you're her family therapist? Am I correct?
KB: Yes.
MP: Okay. l'm here today and I have stated briefly why I'm here is in
reference to an incident that happened to a friend of yours, or a girl you know_
Page 1 of 43
05118
HOUSE OVERSIGHT 012212
2 3   I'm not sure if she's friend of yours or not, by the name of=. Do you know what I'm talking about? Yes.
11   MP:   Okay. I hear your voice got very low all of a sudden so if you don't mind..
5   Oh, okay.
6   MP:   I'll even hold it. Okay. Can you tell me how you know=
7   She's my ex-boyfriend's cousin.
8   MP:   And what's your ex-boyfriend's name?
9   Zack=
10   MP:   Is that his last name?
11   Yes.
12   MP:   What school does he go to?
13   (inaudible) Summit Christian School.
14   MP:   And you said he's your ex-boyfriend. How long ago was that?
15   I don't know. Like two months, two months and a half ago.
16   MP:   How long did you go out with him?
17   Three weeks...?
18   MP:   Not long? And' You met her through Zack?
19   Yeah, I met her when I went to dinner at his grandmother's house.
20   MP:   Okay. And do you know M's last name?
21   No. I don't.
22   MP:   Do you know where she lives?
23   Yes. She lives on streets away from me.
Page 2 of 43
05119
HOUSE OVERSIGHT 012213
MP: Okay.
2 (inaudible)
3 MP: Okay. And tell me now what happened with
4 Okay, well, the third time of hanging out with cause I was a cousin, well,
And we were over there watching a movie and this guy called or actually it
6 was a woman but it was for a guy. -AM!igf.4:§Ni;t4tRi.i6g:ij.
7
8
9
10
11
12
13
14
15
16
17
18
19
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And then we went, I don't know
what day it was cause she picked me up. I'm pretty sure it was a Saturday or a
Sunday. So she picked me up and we get in the car and she (inaudible) and
then we left and we were still driving and then we went to his house and we were
20 waiting in the kitchen and the old man came and he's like, hello, Fm.. .1 don't
21 even know, I think it's Jeff. I'm Jeff and then we, I'm like I'm And then
2.2 she urn went upstairs and I guess gave him money and we went back downstairs
23 we weren't there, we were only there for like 30 minutes and then we left and
Page 3 of 43
05120
HOUSE OVERSIGHT 012214
1 then she went to go to Marshall's to go get some, a skirt and a purse but she
didn't get the skirt. She only ended up getting the purse and that was like a
3 black purse.
4 MP: That's all that happened?
5 Um hm.
6 MP: Well, I'm hearing a lot more happened.
7 Like what, I know, like what went around the school?
8 MP: Like what went around the school. Tell me what happened at school.
9 In school, everybody was saying that I got paid $300 with the, for the old man.
10 That old guy. Cause he's... .oh, first of all, is that I got fingered by the old man,
11 then it was I had sex with the old man and then it was I'm just a prostitute and I
12 got paid $300.
13 MP: Who was spreading these rumors around?
14 Um, my, this girl, she used to be my friend but I guess....
15 MP: Where would she get ....
16 From Zack because I broke up with him. Well, that's what I think. I think when I
17 broke up with him, he got very mad and told the girl cause this girl, she hated me
18 because I went out him and she likes him.
19 MP: Which girl was this?
20
21 NIP: Liked Zack?
22 Yeah.
23 MP:...went out with him so she started spreading these rumors?
Page 4 of 43
05121
HOUSE OVERSIGHT 012215
1 Cause I went out to the fair and she was supposed to go with him but, guess,
2 he didn't like her and then we started talking and she got mad because !was
3 talking to him.
4 MP: What does...can you tell me more aboutM
5 I don't really know that much. All I know is that she, the only thing I know about
6 he: is that her boyfriend, but then they broke up, like, she met him at a party.
7 That's the only thing I know and that she has brown hair and like, I don't really
8 know about her. I went to her house (naudible)
9 MP: Are you telling me?...and I want you to know something, okay?
10 Um hm.
11 MP: Regardless of what has happened, okay? I'm being very honest. You're not in
12 trouble for anything.
13 I know.
14 MP: Whether you did something with this man or not.
15 • Hmm....
16 MP: Whether you did something with this man. What I'm trying to do is fird out if this
17 type of thing is going on and you're not the only one and I don't think you are the
18 only one.
19 I don't think so either cause the other kid Anthony (inaudible) he knows too
20 and I, cause he's telling me, he's like where do you knoMand then I was
21 like she's my boyfriend's cousin. Oh that girl's bad and I'm like okay, too bad.
22 MP: Did you do anything with this man?
23 No, we went upstairs and just got money and I don't know...
Page 5 of 43
05122
HOUSE OVERSIGHT 012216
1 And there's like little circle chairs, that you can sit on.
0
MP: Stools.
Stools. And we were just sitting there waiting cause he wasn't there yet. Then
4 he came inside after we were standing there about 5 minutes. Cause like, there
5 was a gate and a bodyguard guy. When we opened the gate and knocked on
6 the door, security, some guy, like a bodyguard kind of, type of guy. Same guy
7 walked up and he's like, excuse me, what are you here for and we're here to see
8 Jeff. And then he was okay, well come inside. Jeff'll be here in like 5 minutes.
9 And then we waited and he was like you can help yourself to a drink. And then
10 he left and then like 2 minutes after the guy left, Jeff and a lady walked in and
11 they introduced themselves and we're like, hi, my name is and then she's
12 like :inaudible) and then there's like a walk in door thing, that you walk in
13 like a cabinet thing, not a cabinet but the island thing (inaudible) and then the
14 door would be right there.
15 MP: Okay.
16 Yeah, (inaudible)
17 MP: So they walked away out of your sight?
18 Urn hm. Well there was another girl there. I was never by myself. I don't
19 remember the girl's name but she's s friend.
20 MP: Okay.
21 She was
22 MP: What doesM, do you have an idea of what, why this woman, this assistant,
23 would ask if had anybody with her?
Page 7 of 43
05123
HOUSE OVERSIGHT 012217
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
20
21
•
I don't know but what you call, the lady, she really like (inaudible) I don't know
what's wrong. I mean when she walked in, she was like kind of like, I don't know,
but she was just like, urn, she couldn't say anything about her, she was just first
name and that's it and then she was just like right to the point. She didn't try to
be friendly, you know.
MP: What do you mean she didn't try to be friendly?
She wasn't like hi, I'm like, you know (inaudible) she was just like hi, I'm and I
don't remember her name but she said she was from I remember that.
And your friend, or=s friend stayed in the car?
No, she was with us. When we walked in, and she sat, she was just there, she
didn't do anything, she was with me. We were just right at the table, like we
were silting having a conversation for like two seconds. Then=came back
downstairs and then she's like thanks Jeff and then I'm like bye Jeff and then the
other girl was like bye and then we left.
MP: Okay, did tell you what was going on upstairs?
MP:
MP:
MP:
22 MP:
23
No. She just, I didn't ask because like
was to go shopping. That's what (inaudible).
Did she give you any money?
Urn hm.
How much money?
$300.
What did you do with the $300?
I didn't spend it. And then I went to school and then my principal, cause I got
Page 8 of 43
, the only reason I know the money
05124
HOUSE OVERSIGHT 012218
I into a fight with a girl, for saying that. Because she said that I was, had
2 done all that with the old man to get that money and that's not true. That's why I
3 got really angry and then we (inaudible) before that and then when I went to the
4 office to (inaudible) the principal but actually she didn't say anything at first and
5 then she was like, told her side of the story, can I see your purse and I
6 was like go ahead and (inaudible) and I'm like yes and then my dad, my dad and
7 the principal and my step-mom, they were all like urn, why did you do that with an
8 old man and who is the old man. I'll kill him, blah, blah, blah. And then I was
9 like I didn't do anything! I didn't do anything! And they didn't believe me. And I
10 kind of got mad at and then the whole thing, that's when I moved back to my
11 mom's house because my dad thought I was a prostitute. And it was really....
12 MP: You know that just because something may have happened, that doesn't make
13 you a prostitute.
14 I know.
15 MP: Do you?
16 Yes.
17 MR Okay. Do you want something to drink?
18 No.
19 MP: Are you sure?
20 Yeah,
21 MR You know, I've been doing this for a long time and I'm not saying you're not
22 telling me the truth, I think you're not telling me the whole truth about what
23 happened. Okay? Matter of fact, I know you're not. And I know you might be a
Page 9 of 43
05125
HOUSE OVERSIGHT 012219
1 little afraid looking on it....
2 Okay, I... (inaudible) because they already came to my dad's house and they did
3 something to my dad's tires and my dad almost died.
4 MP: Okay. Give me your hand. I'm here to help you. Look at me.
5 I don't want him to get hurt because he already almost killed him.
6 MP: I'm here to help you.
7 KB: Honey, I'm gonna get you some water. Okay?
8 Okay.
9 MP: I'm here to help you, okay? I'm being honest, okay? I'm going to be very up
10 front but I need you to be up front with me, okay?
11 Okay.
12 MP: The only way I can help you is if you're honest with me, a hundred percent
13 honest with me.
14 Okay.
15 MP: Your counselor's not here. Tell me what happened. Now be honest about it.
16 Okay. When I got there, that Jeff guy and the lady were there and then the lady
17 wanted me to come upstairs and she's like, she's talking to me and then she was
18 putting out a table like for a massage. And then urn, and then when and then
19 she like put the covers on the table and they like, it comes to like (inaudible)
20 whatever and she's like, oh Jeff will be up in a second. And then the Jeff guy got
21 there, she was like, she was like, take off your clothes and I didn't know what to
22 do because I was the only one up there and so I just took off my shirt and I was
23 in a bra and then he came in and had a towel over him and he was like no, take
Page /0 of 43
05126
HOUSE OVERSIGHT 012220
1
2
3
off everything. So I just took off my pants and I was in my bra and underwear
and he was like now you're gonna give me a massage. Then he went on the
table and he's like here, the lady that was putting down the table, got out three
4 lotions and put them on the table and then he picked up out which lotion. He
5 was like, give me a massage with this lotion and then I was giving him a
6 massage and he said you can get on my back. So he was on the table and I
7 was straddling him on his back and giving him a massage and then he was
8 turning around and then he whacked offend then he's like oh you have a really
9 hot body and then I was like, that's disgusting, but I didn't say that and then he's
10 like oh, excuse me for a second and he, I guess he went into the other room and
11 he whacked off again and then he came back and said to me like, I'm done. And
12 then he's like, here's your money and then I was going downstairs and he acted
13 all nice and stuff, he's like bye, nice to meet you, hope you can come back again
14 and theM's like how did it go, what did you do. And I'm like, I'm like, he
15 made me give him a massage, and she's like, t know. And then we went
16 to Marshall's and she got a purse and stuff cause she got paid too but I, she
17 didn't do anything, I don't think because she was downstairs the whole time while
18 she knew I was up there.
19 MP: When she asked you to go with her...
20 Urn hm....
21 MP:...did you know...here's your water.
22 Thank you.
KB: (inaudible)
Page 11 of 43
05121
HOUSE OVERSIGHT 012221
1 • Okay. Bye.
2 (Inaudible)
3 KB: Urn, you know what (Inaudible), I'm gonna down to the dorm. She knows how to
4 find me_
5 MP: Okay. You feel better without her here?
6 Yeah, because I'm embarrassed cause it's really gross and she....
7 MP: It is.
8 • ...rnight tell my morn.
9 MP: That's why I'm here. Okay?
10 And I don't want my parents to find out.
11 MP: Weil._
12 Because I told them it wasn't true.
13 MP: Your parents love you. Okay? And their main thing is for you to be healthy,
14 Okay? Not only physically but up here. And they know that right now your have
15 a lot of issues and I think this is one of them. Because like you said, you thought
16 it was gross. Right?
17 Cause he's like 45 years old.
18 MP: That's okay. Let's backtrack a bit. When you went with tell me the part
19 where ii was the truth. Okay? You were with Zack and said let's go?
20 Yeah. Okay, we were watching, I don't remember the movie, but I know we were
21 watching a movie and then we were gonna go and take a ride. Cause me and
22 Zack were gonna get dropped off at the bowling alley so (inaudible) she
93 was saying about her boyfriend and got a phone call and then she was
Page 12 of 43
05128
HOUSE OVERSIGHT 012222
1 talking to that lady and the lady was like, was actually saying I'm
2
corning, I'm coming, and was like, can I bring somebody? And then
3 was like, the lady was like what does she look like and she started describing me
4 and then Zack turned around and said to who are you talking to. And then
5 went like that and she was talking to the lady and like just describing me,
6 what I was wearing that night and then the lady was like okay, well Jeff is gonna
7 want to talk to you and was like, that's fine. And then she got off the
phone and then Zack said, I was like too, why are you describing me, who are
9 you talking to. And she was like , do you want to go with me tomorrow, I'm
10 gonna go pick up some money from my boss's house. And then she's like
11 cause I get paid tomorrow and then I said okay. And Zack's like no because
12 guess Zack knew what she did because Zack said no and he got really mad at
13 me and said no, you're not going, you're not going with her. And then I was like.
14 and she's like, you know, but you just have to come with me and I was like cause
15 the old man's gonna give us both money so we can go shopping. Cause that's
16 like my boss and he's really nice. And I was like okay. And then Zack didn't say
17 anything the rest of the night about it, he was just like really (inaudible) out there
18 and mad. Not really mad but he was just like frustrated that I guess,
19 would soy that.
20 MP: And you didn't know what was really going on.
21 I didn't know it was gonna, that I had to give him a massage and get naked.
22 MP: What did you think was going to happen?
23 That, like she just said, I don't know but I knew something was wrong, nobody's
Page 13 of 43
05129
HOUSE OVERSIGHT 012223
1 just gonna pay you money but I didn't think that I,I thought that was just
2 business whatever do, just gonna go over there. And she told me that it
3 was a rich guy and she was saying oh my God, he's so rich, blah, biah, blah.
4 And he has like a new Mercedes and all this stuff and she's like explaining him.
5 And then, what's it called...so actually we didn't, we left but we didn't end up
6 going to the bowling alley. Her boyfriend went to his house really fast to go get
7 something from his house and then he (inaudible) brought his car back to
8 =Fs house and we were just sitting there watching the movie but she was
9 like, are you sure you're going to go with me and I was like okay, I'll go
10 with you. I'm like last time, I'm like, what are we gonna do we were going
11 to go shopping and we were discussing what we were going to buy with our
12 money, cause she told me how much money I was gonna get, $300. And I was
13 cool, I know what I'm gonna buy. We're just like saying what we were gonna buy
11 with the money. She said I need to go buy a purse and then the next day,
15 actually I gave her my phone number that night so she could call, so she could
16 pick me up. And when I went in the house that morning, she called me, she
17 are you still gonna come with me and I'm like yeah. So she's like okay,
18 get ready. I'm gonna be there in like 30 minutes and then she came to the
19 house in like 30 minutes. And she had a friend with her.
20 MP: Do you remember the name of he friend?
21 I don't know her name but she was like really dark, kind of like a Spanish girl. 1
22 don't (inaudible)...
23 MP: Darker than me?
Page 14 of 43
05130
HOUSE OVERSIGHT 012224
1 Um hm.
2 MP: Okay.
3 And she had like short hair and she had like a styled hair, like a cute little style. I
4 don't remember her name. I talked to her but i didn't remember her name cause
5 (inaudible) right after I got in the car. And then all the way there, we were just
6 listening to music and singing and stuff and like just laughing and stuff. And she
7 told me the girl about her boyfriend and stuff (inaudible).
8 MP: So you're driving. So picks you up. Do you remember what day it was?
9 No but I know it was a Sunday because I told my dad, Dad can 1 please go on
10 Sunday with Haley to go shopping and my dad goes where are you guys going
11 shopping because he didn't know and he said no at first and I was like
12 Dad, that's=, you know Zack's cousin and then my dad says okay but I have
13 to meet her. So then called me afterward and then she's like I'm gonna
14 need $10 for gas and she was like can your dad give me $10? And then I was
15 like sure but I didn't ask my dad, I just (inaudible) $10. And then my dad was,
16 okay and my dad called me, he's like (inaudible) I'm not gonna be able to give
17 you money. So then I was really mad but then I didn't tell but my dad
18 ended up (inaudib'e) (inaudible) when was pulling up, my dad ended up
19 pulling up so and my dad saw each other. And was like, oh my
20 God, your dad is so hot. And then I said yeah, right. Started laughing about it.
21 And then my dad gave Haley $10 for the gas.
22 MP: So you got in the car. What kind of car did she drive?
23 A truck.
Page 15 of 43
05131
HOUSE OVERSIGHT 012225
I MP: What color?
2 I don't remember but I think it was a bluish color. I think so.
3 MP: So she drove.
4 Yeah, she drove.
5 MP: She drove?
6 Yeah and I was in the passenger seat and there was like a whole bunch of junk
7 back behind her and I was sitting next to it, like (inaudible) or stuff for school.
8 And was there... .like but I don't know but it took a pretty long time to get there.
9 And you know where, like, the rich people are, what is that street? Where the
10 Kravis Center is but further than that. Like towards the beach more. That way.
11 MP: Yeah, towards the beach.
12 Yeah. That way. And that's where, yeah, that's like where he lives but when she
13 pulled into, I know for a fact it's a pink house, I remember the pink house and
14 then he had an Escalade in his driveway and then a Mercedes in his garage. I
remember that much.
16 MP: Okay. Do you remember... so you took the Kravis way or did you....
17 I don't remember where we...
18 MP: You don't remember which way...
19 I just remember the building.
20 MP: It was near the ocean?
21 Yeah. I know... .cause one day when I was with my friend , that's
22 exactly where we went, like around that area, not the CityPlace area but you
23 know, it kind of looks like that area. Like where the Kravis Center was and I
Page 16 of 43
05132
HOUSE OVERSIGHT 012226
remember... that's how I remember.
2 MP: Do you remember seeing the beach and the ocean?
3 No but we went over that bridge where the ocean was and then the bridge went
4 over.
5 MP: Okay. So you definitely went over the bridge
6
• Yeah. Went over a bridge. And it was up and we had wait for it to go down. So
7 we were there for like 5 minutes.
8 MP: That was time you were witIM
9 Yes.
10 MP: Okay. And then the house, you said, you described it as pink?
11 It was like a, it was a two story house and then it was like a pinkish color, pinkish
12 pink color.
13 MP: Were there gates or something in front?
14 Well, it wasn't a gate but, the back door had a gate to it and it was a white gate
15 and just like she knew that you had to open it and it wasn't locked so we
just opened it and there were three, two or three steps and you just walk up and
17 then he had a pool and it had, like the floor, the floor was like a hard something,
18 it wasn't concrete, it was squares of like concrete, but they were like...
19 MP: Like tile, you mean?
20 It was like a coral concrete, you know like.. And then the pool was there and the
I house was there, I guess it was like a security house because a man that was
22 with the security came out and he was like what are you guys here for, cause
23 you're knocking on the door and then said we're here to see Jeff and
Page 17 of 43
05133
HOUSE OVERSIGHT 012227
1 then...
2 MP: What did that man say?
3 He was like oh, okay and she's like, she smiles and then he let her in (inaudible)
4 but he opened the door and then we went in and then (inaudible) and the
5 counter, here's the door when you walk in and there's a (inaudible) refrigerator
6 and then the window, a glass sliding window looks out at the pool.
7 MP: Okay.
8 And then like the cabinet, I mean not the cabinet, the island, was like here and
9 then there's like a cabinet over there and the door was right here.
10 MP: Okay, just for the tape purposes, the way that you described it, okay? Is you
11 walk in and on the left hand side?
12 Um hrri.
13 MR Cause you motioned right now, who's there?
14 • (ina udibie)
15 MP: And then when you walked in, on the left hand side, what did you see?
16 Like if I was getting out of the doorway?
17 MP: Um hm.
18 Okay. Well, there's a door. If you looked straight, it would be straight from you
19 but a little towards the right.
20 MP: Okay. And...
21 It wasn't a door, door. It was just a doorway (inaudible)
22 MP: Okay.
23 No, wait, maybe it, I don't know, cause it was open, but there could have been
Page 18 of 43
05134
HOUSE OVERSIGHT 012228
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
door, but it was open so I didn't really pay attention. Buz I know it was a doorway
going up.
MP: Okay. So now you're in that kitchen area Right?
Um hm.
MP: The three of you?
Yes.
MP: Where did you park the car?
In his little driveway area.
MP: So you're in the kitchen area. What happens next?
We were waiting there. We were talking, just about how cool the house was. I'm
like oh my gosh, I've never been in a house like this. And then the lady and the
man came in, Jeff. I'm pretty sure., .like 90% positive. And he walked in, he was
like in a t-shirt and pants, not pants but you know, like maybe like kind of dressy.
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MP: Um hm.
19 •
20
21
22
23
Do you know what I mean?
:reineltri
ut he knew wh :#i*i#MAiikCtfi4.001
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and then he's like okay,
well, then follow my, I don't remember the lady's name but she's, he said follow
her (the name) upstairs. So she's like, come on and then we walked
upstairs and I thought......
Page 19 of 43
05135
HOUSE OVERSIGHT 012229
I MP: By yourself?
2 Yes. but I thought that cause she said she was gonna get paid, so I
3
thought and the girl was gonna get paid in like, you know, like private,
4 privacy and cause it was just him and her and the other girl in the kitchen. And
5 so I went upstairs and as I was walking upstairs, there was a picture of him in like
6 a different country and then I'm like that's really cool and the lady said isn't it and
7 she was just walking upstairs and there was like a door and then, it was like to a
8 little (inaudible) this big and it had a couch and a couch and it was like another
9 walkway towards that way. And then walked towards, like keep walking forward
10 and then to my right and there was a bedroom and then we turned right again
11 and there was a big bathroom, a big.. it was humongous. And the bathroom. It
12 wasn't like a bathroom, bathroom, it was like a sitting area with a shower there.
13 Humongous shower. Like a jillion people could be in that shower. And then it
14 was humongous. And there was like a door here and you opened it and there
15 was like a little desk with paper and pads and stuff. And I don't know (inaudible)
16 like sitting on the couch right here, like against my... there's big long couch. And
17 it was pink and green. Hot pink and green. And there._
18 MP: The roorn or the sofa?
19 The sofa.
20 MP: Okay.
21 And there's a table with a phone on it. And urn, during when I was giving him a
22 massage, he made a phone call but I don't remember whether he just said, like
23 he said four words and then hung up. Yeah, I don't remember. And he made a
Page 20 of 43
05136
HOUSE OVERSIGHT 012230
1 MP: 3y yourself?
2 Yes, but I thought that cause she said she was gonna get paid, so I
3 thought and the girt was gonna get paid in like, you know, like private,
4 privacy and cause it was just him and her and the other girl in the kitchen. And
5 so I went upstairs and as I was walking upstairs, there was a picture of him in like
6 a different country and then I'm like that's really cool and the lady said isn't it and
7 she was just walking upstairs and there was like a door and then, it was like to a
8 little (inaudible) this big and it had a couch and a couch and it was like another
9 walkway towards that way. And then walked towards, like keep walking forward
10 and then to my right and there was a bedroom and then we turned right again
11 and there was a big bathroom, a big...it was humongous. And the bathroom. It
12 wasn't like a bathroom, bathroom, it was like a sitting area with a shower there.
13 Hurnongous shower. Like a jillion people could be in that shower. And then it
14 was humongous. And there was like a door here and you opened it and there
15 was like a little desk with paper and pads and stuff. And I don't know (inaudible)
16 like sitting on the couch right here, like against my... there's big long couch. And
17 it was pink and green. Hot pink and green. And there
18 MR The room or the sofa?
19 The sofa_
20 MR Okay.
21 And there's a table with a phone on it. And urn, during when I was giving him a
22 massage, he made a phone call but I don't remember whether he just said, like
23 he said four words and then hung up. Yeah, I don't remember. And he made a
Page 20 of 43
05137
HOUSE OVERSIGHT 012231
1 phone call and then he put the table back where it was (inaudible). And then....
2 MP: But the lady...so you're upstairs and you're sitting down and the lady's there.
3 What is she doing?
4 Oh, she's, well, there's a closet right here, with a table in it. Like the massage
table...
6 MP: Near the sofas?
7 Yes. Like a door on each side and urn, towards the door, there's a door for the
8 table. She took that out and there's like a safe and then like she put it in the
9 middle. It's this way, like long ways. And then she put like put the cloth over it
10 but she's looking around the room, I guess just to look, like she was
11 remembering something, I guess, like where the lotion was. And there are
12 pictures of like, naked girls on the wall and there was like, there was like one big
13 mural of naked girls' like, butts. And then, towards the door, there was like a
14 cabinet here, like a built in thing, like a (inaudible) and urn, there's drawers in it
15 and she opened the last drawer and there was a whole bunch of lotions, like
16 millions and millions of kinds of lotions. And she picked out three kinds of lotions
17 ard put them on like an armoire kind of thing with a mirror. And she set it there.
18 And then after, she told me, sit here for 5 minutes. Like, just sit there. And
19 eventually he came in and he was like, hi I'm Jeff and I'm like hi, l'rn And
20 he's like, I'll be right back, you can take off your clothes. And then he left. And
21 there's a bedroom out there and he just went out there and I don't know but
22 there's like, pictures out there, I think, I don't remember, he took off his clothes
23 and put a towel over himself. But I don't know if there was a towel thing back
Page 21 of 43
05138
HOUSE OVERSIGHT 012232
there cause it's like, I don't remember...
2 MP: Did he undress in front of you?
3 No, he didn't. But he took off his towel in front of me.
4 MP: Okay. So he came back in....
5 Yeah, he came back into the room and he was....
6 MP: Were you dressed?
7 I was in a bra and he said no, I meant get naked. And then I was, I went like that
8 and he was you can keep your bra and underwear on and but get down to your
9 bra and underwear so I took off my pants. Cause he was real stern about it, like
10 Take Off Your Pants. And then I just took off my pants and then he laid down on
11 the table but like, after he was laying on the table, he took off the towel just
12 enough, you know, like you could see....
13 MP: Did you see him naked?
14 Yes I did. And it was disgusting.
15 MP: I don't mean to... I know maybe it's disgusting but can you describe him? Did he
16 have any marks, tattoos, was he hairy?
17 Yes, he was really very hairy on his chest and on his back and towards.. okay I
18 don't mean to sound gross but....
19 MP: No, say it the way you would if you were speaking to one of your best friends.
20 Okay.
21 MP: (inaudible)
22 Okay. He was laying on his belly side so his butt was like, up. And there was
23 like, he had a very hairy back all the way to here and then there was just like a
Page 22 of 43
05139
HOUSE OVERSIGHT 012233
hairy butt line going down to his butt.
2 MP: Okay.
3 So gross. Okay, and then. (inaudible)
4 MP: Did you see the front of him?
5 Yeah. Cause when he got off the table, he like turned this way so everything
6 showed towards me and then he got off and then he went and whacked off and
7 then he came back in. But he was very hairy on his chest area and I just looked
8 for like one second and it was very, very disgusting. Okay. That's all I have to
9 say about that.
10 MP: Do you know what it means....and I have to ask only because there are some
11 people that don't.....to be circumcised?
12 No. I don't, I don't really know... but I think he was on steroids because he was a
13 built guy and his weinie was very tiny.
14 MP: His wee wee was very tiny.
15 Yes.
16 MP: And when you mean wee wee, you mean what?
17 His penis.
18 MP: Yes, his penis. Okay.
19 Yes, his penis.
20 MP: People calf it different things. Alright. I just wanted to make sure we know.
21 Okay. He laid down, he took off his towel and he laid down.
22 He laid down on the
23 MP: Did he take his towel completely off or just open it so...
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I No, completely off.
2 MP: Okay. Where did he put the towel?
On the floor. Right like, the table underneath.
4 MR Okay. So he laid down, took the towel off. What happened next?
5 And then he's like, get the lotion. So I grabbed the lotion. Which, I had to walk
6 almost naked, but I was in like a thong so yeah, my butt was showing and he, the
7 table is like, I mean the sink was, you know, the lotions were right there and I
8 was over here and he was like go get the lotions just so I could walk past him
9 with my butt showing to go get the lotions. So I got the lotions and he's like, he's
10 like this lotion and then I took that lotion and he's like squirt it on your hands and
11 then massage clockwise on my back cause I didn't know how to do it? and then
12 he's like telling me where he would like the massage, here and here, the right to
13 the left, down more, up more. So I was just massaging and he turned and
14 started having a conversation, oh what happened to and I'm like,
.15 (inaudible) my ex-boyfriend (inaudible) what's your boyfriend's name. Zack. And
16 he was kind of questioning me and then he said what, he's like, could you stop?
17 1 need to go. And i just stopped and I'm like okay. And he got off the table. He
18 put the towel over him. He bent down and got the towel and then he left the
19 room and you could hear him, like, you know, you could obviously tell what he
20 was doing, just like....
21 MP: I don't ..... I won't look at you but do what he was doing, what you heard. I know
22 it's kind of embarrassing but....
93 He was making like sex noises. You know, like..... I don't.. They were very
Page 24 of 43
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I strange noises. That's all I can say.
2 MP: Okay.
3 I don't know how to describe them, they were very strange.
4 MP: Can you imitate them?
5 I don't I don't want to make a fool out of myself.
6 MP: You won't. You're not making a fool. You know, it might say it's sex noises. He
7 may say I was singing.
8 Okay. He was like....
9 MP: I won't look at you, go ahead.
10 He was like 0000hhhh, 000hhh.
11 MP: Okay, okay, he's making groaning noises.
12 Yes, groaning noises, that's it. Okay. That was really embarrassing. It really
13 was. He was making those kinds of noises and then he walked back into the
14 room, took off his towel again and laid back on the thing and then he wanted the
15 same kind of massage but he was like oh use your (inaudible) a little bit more.
16 MP: You were massaging his back?
17 Yeah. And then he, he's like, could you, turn over for a second.. (inaudible)
18 (inaudible) go back out of the room. He turned over and he said okay, please
19 massage my boobs. And then I was massaging his boobs and he's like. he's
20 like, oh, like as I was doing it, as I was massaging, he was making the same
21 noises again like, oh my God, it's so embarrassing to do this. He was like....
29 MP: I won't look.
23 Ho was going like 000hhh, making those noises. And like 5 minutes after that,
Page 25 of 43
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1 and then he turned back around and he just started touching himself and I think
the massage was like a half an hour but cause I don't know, the time I think was
3 a half an hour to 45 minutes and then I was done. And then he, I think he has
4 like a safe somewhere because around us he didn't have his wallet or something
5 because right when we got out the door, he left to go put the towel on again and
6 he put the towel on again and went out of the room and he goes you can put
7 your clothes back on. So I put my clothes back on and he walked right out there,
8 like two seconds and then came back like within two seconds. And he's like
9 here's your money. And then he gave me $300 in hundred dollar bills and they
10 were like brand new because they only had like one crease in them and that's
11 when they're folded in half. And he said thank you for your time. And then he
12 left. And he said you can see your way out and I was just walking and I got lost
13 cause there's so many different rooms and I got lost and I walked back
14 downstairs and was like just smiling and giggling, like, I guess it was what
15 the lady was saying and then she looked at me and she looked back at the lady
16 and then she's like, the lady's like oh, bye cause it was time to go cause I
17 guess because I was done. And then, then we left the same way we came in
18 and then s like oh my gosh, Mgoes how did you like it. Like how much
19 did he give you, how much did he pay you. And I'm like $300. And I was kind of
20 like $300, Cause the girl was like this. She was looking at me really weird.
21 The other girl that was with her. She's like really quiet though. And then she just
22 looked at me really weird and she's like trying to gaze into my eyeballs. And
23 then we went in the car and when we got in the car, s like, let me see what
Page 26 of 43
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1 he gave you. And then I showed her my $300 and she's like, we're going to
2 Marshalls. And then, give me back my money and I put it in my back pocket.
3 And then she was trying to get me to describe what happened so told her what
4 happened. And she's like, you could do this every Saturday. He's is like so rich_
6 And I was just kind of like, yeah, we could. And then, she put back on the music.
6 And then, when we were leaving, the lady was walking outside and I (inaudible)
7 one of the cars really fast but she was just going to the passenger seat and she
8 opened the door and then closed it.
9 MP: What did •s friend say? Did she say anything about it?
10 She was just like interested in what happened, like when we were talking, we're
like into the conversation and then she was kind of like giggling and laughing,
12 like, I think, I wouldn't say, I mean, I don't know if (inaudible) or not but she
13 wasn't acting surprised, you know, like giggling. She was -just of like giggling and
14 laughing along with And tnen=goes urn, and then when I was giving
15 the guy the massage, he goes, I know she's been working with me for a
16 long time and then when I came back downstairs, goes, you only paid me
17 $200. So....
18 MP: He liked you better.
19 I don't know.
20 MR Well, after you left, where did you go?
21 Marshalls or to TJ Maxx, one of those two. TJ Maxx or Marshalls. And she
22 bought a black purse.
23 MR Okay. Did you see after that again?
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1 Urn, I don't think so because that's when I got grounded. And then that's when I
got in trouble with the fight. So after that, I'm pretty sure I didn't. Most likely.
3 MP: Did you ever speak to her again?
4 No, because I got my cell phone taken away.
5 MP: Okay. So you haven't see since the day you went to Jeff's house.
6 Correct.
7 MP: Are you sure?
8 Yeah. I'm 100 percent sure.
9 MR How do you know she....now tell me what happened with your dad
10
• Okay. Because my dad, I didn't know about until my sister told me when she
11 came here. But my sister, on a Thursday, was coming here. And wait,
12 Wednesday night, my dad said that he heard the dog barking and my dog is
inside. So he's barking and he's outside, like barking towards outside and then
14 my dad is like shut up cause he forgets the dog's name and the dog wouldn't be
15 quiet. So he's like, I'm taking the dog outside. And then my dad took the dog
16 outside and the dog was way in towards my dad's truck, like my dad thought he
17 was attacking the animals but my dad, a person, a boy, don't know for a fact
18 but I know in my heart its Zack. Because Zack got really mad over the whole
19 situation.
20 MR Did you tell Zack what happened?
21 Yeah. And that's when, he punched a wall and he like my face was right there
22 and he punched the wall, like my face was right there and he punched the wall
23 right next to my face. And he started getting all upset and crying and calling
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I how could you do this? Blah, blah, blah. And then 's like, okay, I
2 won't do it again. And like she just kind of like hung up and he was like I hate
3 her, I hate her and then I hate you too. And I was like okay and we broke up and
4
then I think (inaudible) on the computer and I think he told what
5 happened and she turned it into an extraordinary, like story so at school so
6 would look like, you know, like I'm the bad person, like I'm a slut, I'm a whore or
7 something and she's going around school saying all this stuff and then so my
8 parents came, cause that's when I got mad at her and told her to stop talking but
9 she wouldn't stop talking about it. So I just got in a fight with her, like a fist fight
10 at school. And I got suspended and so did she but she only got suspended for
11 one day because I started the fight So I got in trouble more. And my dad got
12 really mad and he grounded me for it, because he found the $300 in my wallet
13 and then my dad was like, you're grounded, you're grounded forever and he's all
14 freaking out, how could you do this, blah, blah. The school said you did. And
15 urn, I didn't tell the school how, I told them I got it from my job, cause I worked at
15 Chick Filet but I quit. So I said I (inaudible) but nobody believed me so I was just
17 like believe what you want. Cause I didn't want to tell the principal or my
18 parents.
19 MP: Well, I think that the best thing that you're doing is that you're being honest.
20 Okay?
21 Umhm.
22 MP: You already know that they have a pretty good idea what happened. Okay?
93
I didn't even know there was like an investigation.
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I MP: Well, that's....
2 I just knew.
3 MP: Well, this is why. What's happening is that I was made aware of this situation...
4 From my school?
5 MP: I'm not gonna say, okay? I was made aware of this situation. And they look at it
6 like you were taken advantage of. Not that you did anything wrong, okay? Even
7 though you went there willingly. Even though you went there willingly, you were
8 still taken advantage of. Okay? Because you were put into a position that you
9 felt you had no choice. Once you were there, before when you were telling me
10 about how Jeff told you to take off your clothes? You took your pointer and you
11 said he was really stern and you banged your leg, you put the pointer on your leg
12 when you said that. How did you feel when he told you to take your clothes off?
13 I don't know. I didn't know what else to do because I was the only person up
14 there and he's like 45 years old and he has like big muscles, because, I don't
15 know, but I'm pretty sure 45 years old and big muscles, body builder.
16 MP: Okay.
17 So I just felt intimidated because he's guy, first of all, and I'm a girl and I know
18 that was all the way downstairs with the lady and what was =ligoing to
19 do to help me all the way upstairs so I just did it.
20 MP: Okay. Now, there's one way I'm a little confused at because you said that, and
21 I'm using your words okay, that he whacked off twice. You said before that he
22 whacked off twice. When did he do that?
23 In between giving him a massage, like when I was giving him a massage, he was
Page 30 of 43
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got, he was like, excuse me for a minute and he just left the room.
2 MP: Okay, so that's once. When was the other time?
3 Like during the thing, like when I was massaging his boobs.
MP: When you..okay, when you were massaging his boobs, was his back flat on the
5 table? How was he positioned?
6 Well, he was at first and then when he started to whack off, he got like, his back
7 went off the table, kind of like leaning...
8 MP: Okay, where were you standing?
9 I was standing up. I was not on him. I was standing up (inaudible) and I was
10 like....he was towards, okay, he was on the table. I'm right here and he's leaning
11 that way.
1') MP: Okay.
13 ..like (inaudible) cause I guess, I don't know, but.. and he was like, my face, it
14 got hard to see what was going on because of how low I was and he just kind of
15 moved his head the other way and he was like, wants....
16 MP: Okay, but just now, when you're saying that, you moved your hand. Did you see
17 him whacking off?
13 Yes. I saw him whacking off.
19 MP: Okay. That's what I need to know. Cause you said he whacked off twice.
20 Urn hm.
21 MP: So he whacked off in front of you?
22 Um hm.
23 MP: And you saw his hand doing or you saw his eyes, what was going on?
Page 31 of 43
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I Okay. I saw his face, facial expressions and noises.
2 MP: Okay. What else did you see?
3 I just saw him...
4 MP: You keep moving your hand so...in other words, he took his hand and what was
5 he doing with his hand?
6 I don't know how to explain it. He was just whacking off.
7 MR Okay, describe.. don't....
8
• Okay, sorry, he put his hand on his penis and he put it up and down and he was
9 like making facial noises, I mean facial expressions and making noises.
10 MP: So you saw him doing that, he did that in front of you?
11 Yes.
12 MR Do you know what it means when someone ejaculates?
13 It means they're horny?
14 MR No, what it means is that once they, while they're whacking off and I'm using
15 your words, okay. Another word for that is masturbating. Okay?
16 Yes.
17 MP: Do you know what it means to masturbate? A boy does it?
18 I don't know why they do it or I know why they do it but I don't know what it
19 does...
20 MP: Okay.
21 To them.
22 MP: In other words, fluid comes out of their....
23 Oh, okay.
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1 MP: Okay? I'm just being very... I'm gonna tell you because I think....
2 I know that part.
3 MP: Okay. So fluid comes out and that's ejaculating And it's called semen. So
4 while he was whacking off, okay, did you see any fluid come out?
5 It was, yes, because he had to take the towel and wipe his thing before he got off
6 the table again to go get the $300.
7 MP: Okay.
8 He took the towel and like... And then, okay, like he took the towel to wipe
9 himself and then like as he was getting off and then this way instead of this way,
10 this way, like that.
11 MP: Okay. Since you've seen his penis, was there anything distinctive about it? Like
12 did he have a mole on it?
13 No, it was very small.
14 MP: Very small, that's fine. Did you notice.. you said he was very hairy on his chest.
15 Did he have any tattoos?
16 Uh uh, not that I saw.
17 MP: Did he have any scars?
18 No, but he had freckles somewhere because he was huge.
19 MP: You're pointing at the chest area.
20 Yeah, some freckles.
21 MP: Like a mole or a freckle?
22 A freckle.
23 MP: Okay. Can you tell me what he looks like?
Page 33 of 43
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1 He had like not white hair but it was, not white but it, you know, it was kind of like,
2 like me. It was like.... I don't know.
MP: He was going gray.
4 Yes. He was going gray. And he had...
5 MP: What color hair did he have before? Blonde, brown?
6 No.
7 MP: You were describing Jeff to me, with the freckle and he was going gray and what
else?
9 Urn, like he, like his skin color is like, when I saw him, when you have a sunburn,
10 but its like when you have it a couple of days and its turning into a tan. It was
It like a reddish tannish color. And he had like a long face and that's about all I
12 can remember and he had a white t shirt when he first came in.
13 MP: Okay.
14 I don't really remember...
15 MP: Did he have any king of like jewelry on his body that you noticed?
16 I didn't, I don't remember_
17 MP: Okay. Do you remember what color eyes he had?
18 Nope.
19 MP: Did he have any facial hair, like a mustache? Or a goatee or anything?
20 Hmm....No but his eyebrows were really thick and they were bushy, like
21 everywhere.
22
23
M4.6056jrA
her
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
YVer:
•
f'040
Yes,
.63;v30.0.011.03,
MP: Okay. You said that you straddled him.
•Um hm.
MP: What do you mean by that?
When..he was on his stomach and I was giving him a massage, like I was, you
know where, like, on...on, like the butt? And then like, I was sitting on his butt
but a tittle bit above his butt And 1, it was, I was butt naked and he was butt
naked and....
MP: Okay.
...my butt was, my butt cheeks were on the top of his butt and the real little of his
back.
9p.gp4
MP: Okay. Now, did he ask you to get on top of him?
Um hm.
MP: Or did you do that on your own?
No, he's like. .because at first, I was giving him a massage like you know,
standing up. And he, then he's like it would be feel more comfortable if you got
on my back. Could you please do that. ...and then I did that. Like, I did, urn, like.
Page 35 of 43
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HOUSE OVERSIGHT 012246
1
2
3
4
5
6
I wasn't, at first I didn't want to sit on his hairy you know, butt. So it was kind of
like, you know, like, pushing my legs on the table so like I could kind of sit up and
he was like could you please just put all...like sit on me, put all your body weight
on me. And then I went, I was just kind of like kind of think I did when I was
actually sitting on him, I didn't realize what it was and then like, I got grossed out
and as I'm going down, kind of like popped up again. Cause it was gross.
7 MP: Okay. He never tried to touch you?
8 Besides like, you know, well, what do you mean by touching, like sexually
9 touching me?
10 MP: No, did he try to touch you or...
11
He put his hand on my back when he was whacking off or masturbating. Like,
12 he was just like....
1 3 MP: You keep, like motioning, like smacking.
14 No,...
15 MP: What do you....
16 Like, when you're leaning on something, putting your force on it? He was going
17 like that, fike...pulling, not, you know, like._
13 MP: Can you shovv me what you me.an?
19 Okay. He was
20 MP: Let's say I'm on my back. Where would you be, l'm Jeff, where would you be
21 standing?
22 I'm right here. I was like, I was like sitting right here.
23 MP: Okay.
Page 36 of 43
05153
HOUSE OVERSIGHT 012247
1   Okay and when he backed up.
MP:   Which way, this way?
3   Yeah
4   MP:   Okay, I'm going to my left.
5   All the way around til your back's on the table.
6   MP:   Okay. I'm facing you.
7   And then you're, your face is a little bit that way...
8   MP:   My right. Okay.
9   And (inaudible) towards, like on his knees, kind of....
10   MP:   Okay, I'm hunched over a little bit.
1'1   And I'm over here. And I'm still giving you a massage and everything but this
12   hand is around me and (inaudible)
13   MP:   Okay. My left hand would bc...so is my left hand around your shoulders?
14   No, under my arm while I'm going like that...
15   MP:   Okay. So I'm holding you like around by the waist.
16   Urn hm. And that hand was on his...
17   MP:   His right hand.
18   Yes.
19   MP:   Okay. It just gives me a better picture of trying to understand, that's why.
20   Um hm.
21   MP:   And I appreciate you doing that. I don't mean to make you feel uncomfortable_
22   Do you feel uncomfortable?
23   No.
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MP:
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Okay. After everything was done, okay, did he watch you get dressed?
No. Cause i was getting dressed while he was out there getting the $300.
guess that's what he was doing. That's the only thing he came back in with. He
was still in a towel and stuff.
MP: In the room, at all, do you think...and I don't know if there is or not, but do you
think there is anything in there that may have recorded what you did'?
Oh my gosh....
MR A video camera...
Oh my gosh. I didn't think about that. There was lots of places there could have
been one because there's pictures, that could have been, I don't know....
MP: When he walked out... the reason why I ask is because he walked out once and
then came back in, right?
Yes.
MP: So it could be just so he could whack off. I was just curious. I don't know if
there is or not.
If there was, I did not know about it.
MP: Okay. So you get dressed, you go downstairs. Where is that woman again?
18 Downstairs talking to and the other girl.
19 MP: Okay.
20 They were having a conversation.
21
22
23
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Page 38 of 43
05155
HOUSE OVERSIGHT 012249
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
use :5e
6tifikMidt4tii0v.go
So said he wss 18 As k*O'CrO;StilitliNftEkffi0;40§04:fj
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MP: So what other things did he ask you?
Urn, how I know what school I went to.
65#40i1AK01:#00:::1§.. gr*
0.6061).
MP: Did you tell him what school you went to?
Yeah but I told him Wellington. I didn't tell him Royal Palm.
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rac
because laid him Was 8 so I had to.
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MP: Okay. What else did you talk about?
20 Urn, that's about it. And he was kind of asking me like how I knew=, is
21 nice to me and then he told me how he knevMand he was like, I was
22 kind of like, how do you know= Cause I brought up the conversation. He
23 said well I know Haley because she's been working for me for a long time. And
Page 39 of 43
05156
HOUSE OVERSIGHT 012250
I then like, I kind of, you kind of get the picture, working for you and hello, I'm
2 sitting there giving him a back massage. So I kind of figured it out.
3 MR He never said that, he just...
4 Yes..
5 MP: ...said that she worked for him.
6 Yeah but don't...on our way back home, that, like, doesn't make any sense if she
7 didn't do that because why would be doing (inaudible) for almost the same
8 amount of money as me.
9 MP: Right. Well, why couldn't he pay her that day?
10 I don't know, because that's a good question. Cause she didn't, as far as I know,
11 but I don't know but I'm pretty sure she didn't tell me. she didn't think. She was
12 just downstairs having a conversation. And I think that when I went up to the
13 lady, he paid her because like, you know, so because, he paid her while I went
14 upstairs and when I went downstairs, she was still talking to the lady still and she
15 goes, when we were in the kitchen waiting, the old man to come to the house
16 still, she said, oh the chef is so hot, he works here and she was like, and she's
17 like he's so hot, you know, saying his face and then the other girl (inaudible)
18 because when we saw the chef come in, he was old, too. He was like...
19 MP: So likes older guys.
20 Must like it.
21 MP: Okay. So you left and that was the last time you see him.
22 Yes and that's the last time I went....
23 MP: Has Jeff ever tried to call you?
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HOUSE OVERSIGHT 012251
1 Nope. And...
2 MP: Did you leave a phone number?
3 Yeah. Actually I did. Cause when I was leaving, he goes urn, please leave your
4 phone number so can keep in touch with you because she doesn't have
5 your phone number. So I didn't, I just gave him my cell phone number. I didn't
6 give him my house number, I gave him my cell phone number.
7 MP: And how long ago was this?
8 Oh my gosh, I couldn't tell you the date but....it was about maybe, oh my gosh, a
9 month and a half ago. I don't really know..
10 MP: In February?
11
12 MP: Because we're in March right now.
13 Either the very beginning of February or the end of January. I couldn't tell you...
14 MP: How tong after did you get into that fight with
15 Urn, like a week, cause...
16 MP: You got into a fight with on the 9.
17 Okay, so yes, it was about a week after... .or before.
18 MP: Okay. And who else besides Zack dic you tell what happened?
19 That's it.
20 MP: Besides of course.
21 Zack and
22 MP: Do you think has brought anybody else that you know of?
23 No, but she wanted me to bring my sister but that same day was going to her
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HOUSE OVERSIGHT 012252
1 boyfriend's house.
2 MP: Okay.
3 And, when I was in that guy's room, there was a like, where the drawers of lotion
4 were, there's like a shelf of pictures and he had so many pictures of girls about
16, 17, around that age, 17 or 18. And they were like on the walls and most
6 of....all the girls were topless or just plain naked And they were in positions or
7 they were just standing up.
8 MP: Okay.
Looking at pictures.
10 MP: Okay. Well, I have to ask you. Do you know the difference between....and
11 you're a grown woman, so I'm asking you. You're pretty mature for your age.
12 Okay? Do you know the difference between right and wrong?
13 Yes.
14 MP: Do you know the difference between the truth and a lie?
15 yes.
16 MP: Can you tell me what a lie would be?
17 Urn, not saying the truth.
18 MP: Okay. So if I tell you you are wearing a blue sweater right now.....
19 I could tell you you're lying,
20 MP: Why?
21 Because I'm wearing a pink one.
22 MP: You got it. Is everything you've tod me the truth?
23 Yes.
Page 42 oi 43
05159
HOUSE OVERSIGHT 012253
1   MP:   Are you lying about anything?
2   No. I'll swear on the bible.
3   MP:   Okay. Swearing to God, that's good enough for me.
4   I swear to God.
5   MP:   Okay. Is there anything else you'd like to talk to me about?
6   No, because that's about....nothing else about the whole thing.
7   P.M   WtIktoot,have any kind of sec with hm
8
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10   OW'W ViijO me Y mee
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15
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MP: At any time, did he touch you
At no 1ime...
MP: Besides putting his hands...
Besides that, no times did he touch me.
MP: And just so I can be sure, you saw him whacking off once.
Yes, I saw him.
MP: Okay. And as far as you think.....
I think, I know, well, I couldn't say / know, but it's the same noises were being
made when he was (inaudible).
2'
MP: And that's it. I thank you very much. This will conclude the interview. The time
23 now by my watch is approximately 3:05.
Page 43 of 43
05160
HOUSE OVERSIGHT 012254
TAB 5
HOUSE OVERSIGHT 012255
sor & Associates
Ropciritog 'gad TroinalaipOiow, No.
Page 1
THE STATE OF FLORIDA,
COUNTY OF PALM BEACH.
IN RE:
JEFFREY EPSTEIN.
SWORN STATEMENT OF
Friday, March 21, 2008
12:05 p.m. - 12:15 p.m.
250 Australian Avenue South
Suite 1400
West Palm Beach, Florida 33401
Reported By:
Judith F. Consor, FPR
Notary Public, State of Florida
Consor & Associates Reporting and Transcription
West Palm Beach Office
Phone - 561.682.0905
greid ft.:SA.114a Ivac41 st.a.koRaWn
HOUSE OVERSIGHT 012256
sor & Associates
Rslox* wed Thtnaciripdoll,
Page 2
APPEARANCES:
2
3 On behalf of the Defendant:
JACK A. GOLDBERGER, ESQ.
4 ATTERBURY, GOLDBERGER & WEISS, P.A.
250 AUSTRALIAN AVENUE SOUTH
5 SUITE 1400
WEST PALM BEACH, FLORIDA 33401
6 561.659.8300
7 ALSO PRESENT
LILLY ANN SANCHEZ, ESQ.
8 FOWLER WHITE, ATTORNEYS AT LAW
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
HOUSE OVERSIGHT 012257
or St A5sociates
RePurthrig mulTransedpiteg,
1 2   Page Statement taken before Judith F. Consor, Court Reporter and Notary Public in and for the State of
3   Florida at Large, in the above cause.
4
5   Thereupon,
6
7   having been first duly sworn or affirmed, was examined
8   and stated as follows:
9 10   THE WITNESS: Yes, ma'am. BY MR. GOLDBERGER:
11   Q. Jennifer, my name is Jack Goldberger and
12   I'm here with Lilly Sanchez. And we are two lawyers that
13   represent Jeffrey Epstein in some matters that are being
14   investigated here in Palm Beach County.
15   We've asked you to come in here today, and
16   we really appreciate that you came in here voluntarily.
17   You've just been sworn to tell the truth,
18   and really all that means is that we're going to take a
19   statement from you. And it's obvious that we just want
20   you to tell us what you know.
21   A. Uh—huh.
22   Q. We don't want you to tell us anything that
23   is incorrect or a lie in any way. We simply want the
24 25   truth here. And we're going to do this very, very quickly. Okay?
HOUSE OVERSIGHT 012258
sor & Associates
Rworlin Auld Tarrivaiptivq.b.
1
2
3
4
6
Page 4
A. Uh-huh.
Q. If you don't understand -- you know, I talk
in what's called lawyerese sometimes. And if you don't
understand what I'm saying, just say, "Jack, what are you
talking about?" And we'll get it straight for you.
Okay?
7 A. Uh-huh.
8 Q.
A.
Will you tell me what your full name is.
10   Q.   Okay. And your birthday,
11   A.
12   Q.   Okay. Now where do you live right now?
13   A.
14   Q.   Is that here in West Palm Beach?
15   A.
16   Q.   How long have you lived there at that
17   address?
18   A.
19   Q.   And you live there with your son?
20   A.   Yes. And my parents.
21   Q.   Okay. You've never been in court before
22   for anything,   have you?
23   A.   Traffic. .
24   Q.   Your own traffic?
25   A.   Nothing, nothing serious.
HOUSE OVERSIGHT 012259
sor 82. sociates
RwrgndThirmripsiival, 1114,
Page
1
2
3
Q. Just your own traffic matters?
A. Yes.
Q. Have you ever had to have an attorney
4 represent you for anything?
5
6 Q. Good for you.
7 Okay I want to talk Lo
8 you know by the name of Jeffrey Epstein.
9 A.
10 Q.
11
12 Q. owitaft J66'gd '6WY ' '
13
14
15
16
17
18
19 Q. And what had told you about
20 Mr. Epstein?
21 A. She told me that he was having girls such
22 as
23 names, were setting up girls to bring them over and give
24 him massages, and it was going to be strictly massages,
25 no physical contact other than that, and that I would be
A.
In
A. No.
you
about a man that
Uh-huh.
You know Jeffrey, do you not?
I met him once.
0:110g
Q. Okay. And now before you went to Jeffrey
Epstein's house, had you ever heard of him before?
A. Yes, had told me about him,
and , and others that I don't know their
HOUSE OVERSIGHT 012260
sor & Asso iate5
Paniorting eaa Tramnririto, top,
Page 6
1 getting paid -- I don't remember what she told me. I
2 3 4   think she said a hundred dollars for a half-hour or something, two hundred; either a hundred or two hundred. I can't remember. It was a long time ago. Q. Sure.
6   A.   But it was only going to be for a half-hour
7   and that was   it.
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HOUSE OVERSIGHT 012261
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HOUSE OVERSIGHT 012262
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Page 8 1
1 0:44A1,0AtAii0444,F
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3 440:
4
5
6
7
Q.
olcaY
hone CantaCt, I'M Including text
Y other kind of contact th Way YOU
So thexe. wa,$ no contact at all?
Okay. Now, I think you just what answered
8 the question, but let me just ask -- I'm going to do what
I told you I wouldn't do; I'm going to ask it to you in
legalese. Before going over to Mr. Epstein's house, did
anyone try to persuade you to engage in that kind of
sexual activity or sex with Mr. Epstein?
A. No.
Q. Okay.
A. When had -- because was the
one that had drove me over there --
Q. Right.
A.
told me that would be the
one driving me -- they were following -- and had
said that if -- he might ask if I wanted to do anything
else, that it was up to me, I could say yes or no. She
said, "He may ask you to do other things."
Q. But no one was asking you before you --
A. No one was telling me that I had to do
3
anything. She was just stating that it was a possibility 2
HOUSE OVERSIGHT 012263
5or 8,1A55ociates
Rsportiag ixad traum-iption,
1 he may ask me to do other things.
2
Page 9
Q. Most importantly though, before you went
3 over there, no one tried to persuade you to engage in any
4 kind of sex?
5 A. No, no one persuaded me.
6
Q. No one was inducing you or enticing you to
7 do any kind of sex?
8
A. No.
9 Q.
Okay. And certainly no one that had any
10 association with Mr. Epstein tried to persuade you or
11 induce you to engage in any kind of sex?
12
A. NO.
13 Q. Okay. As far as what said to you,
14 she said he may ask you whether you want to do anything
15 and it was totally within your rights to decide?
16 A. Totally within my rights to do whatever
17 wanted to do.
18 Q. And I assume she told you that if anything
19 was asked of you, whether you wanted to do anything else,
20 I assume told you that Mr. Epstein would
21 absolutely respect that. In other words, if you were
22 asked to do anything and you said no, he would say,
23 "Fine. I understand."
24 A. Yeah. Because he told me in the room if
25 didn't want to -- whatever I didn't want to do, just say
etdaskcisosax. * T
HOUSE OVERSIGHT 012264
no and he said that was fine.
2 Q. Okay.
3 A. That's what I was understanding.
Q. Okay. But that conversation only took
place after you got to his house, right?
A. Yeah, right.
Q. Okay. And going back to, to , she
8 never communicated to you, with you by e-mail or text
messaging about any engaging in any kind of sexual
10 activity?
11 A. No. It was just that day that I had
12 decided that I was going to go over there that had
13 took me over to 's house and then had drove
14 me there and and followed.
15 Q. Okay. I know the answer to this is
16 obvious, because you only went there to Mr. Epstein's
17 house one time, but I've got to ask you this. You never
18 traveled anywhere with Mr. Epstein, did you?
19 A. No.
20 Q. You never left the state to meet with
21 Mr. Epstein, did you?
22 A. No. Heard other girls did.
23 Q. Okay. Ms. Sanchez just reminded me of a
24 question I forgot to ask.
25 You never spoke to on the
HOUSE OVERSIGHT 012265
sor 81 Associates
litnporxin$and Thall014492i. TIM
Page ll
1 telephone at any time, did you?
2 A. No.
3 Q. Thank you.
4 So I think what I'm hearing you tell me is
5 that your going over there was entirely voluntary; it was
6 consensual on your part?
7
A. It was consensual on my part, yes.
Q. No one told you that you had to dress in
9 any particular way?
10
11
12
13
A. No. I was wearing jeans and a tee shirt.
Q. Kind of like today, right?
A. Exactly.
Q. Now, you were told that you didn't have to
14 take your clothes off, right?
15 A. Yeah. She was -- well, they told me it was
16 up to me. They said that it was just going to be a
17 massage. They didn't tell me anything further than that.
18 They said if he did ask me, it was entirely up to me.
19 Q. Right.
20 A. And that was that.
21 Q. Right. And you were told you could say no
22 to anything if anything was asked?
23
A. Yes.
24 Q. And that was clearly the atmosphere that
25 existed when you went to the house?
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HOUSE OVERSIGHT 012266
5or & Associates
R.oputibg and Trearoxiptiva, w.
Anything that was done was totally your
Now you never -- during the one time that
you were with Mr. Epstein, you never told him at any time
that you were uncomfortable with him in any way, did you?
You weren't afraid to say no to him about
Nothing. Or anybody.
Did he ever touch any of your private parts
MR. GOLDBERGER: Let's go off the record
(Discussion held off the record.)
MR. GOLDBERGER: Back on the record.
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HOUSE OVERSIGHT 012267
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Ckx his chest and his
3   Q.   Okay. Now while you were with Epstein, did
4   he touch his penis at all?
5   A.   No, he did not.
6   Q.   Did he masturbate in front of you?
7   A.   No.
8   Q.   And you didn't touch his penis, I assume?
9   A.   No.
10   Q.   You didn't help him masturbate?
11   A.   No.
12   Q.   And certainly --
13   A.   Sorry. He was too old.
14   Q.   I hear you. And I'm sorry to ask these
15   questions that are so obvious.
16   A.   It's your job.
17   Q.   Mr. Epstein did not have any sex with you
18   in any way?
19   A.   No.
20   Q.   You didn't have any kind of oral sex with
21   him?
22   A.   No.
23   Q.   Okay. Did Mr. Epstein ever penetrate you
24   in any way with his finger or anything?
25   A.   No.
awsnicaw-tIkkwe..,2136Ateadah.e.
HOUSE OVERSIGHT 012268
6ar & As5ociates
FtripprtimF aid Tnamccriisiem, Tin
Page 14
1
2 been telling me, that Mr. Epstein never threatened you in
3 any way?
4
5 Q.
6 a nice guy, right?
7
8 sit here and actually defend him, because I know he was
9 wrong for some parts maybe in his case, but as far as T
10 go, it was -- he was not threatening me. He didn't make
11 me do anything that I didn't want to do. I said no if I
12 didn't want to do something and --
13 Q.
14 were there or anything like that?
15
16 Q.
27 you drugs of any kind?
18 A. No.
19 Q. Okay. He didn't offer you any alcohol?
20 A. Nothing.
21 Q. And I think you told me already -- but
22 let's make sure we're clear on the record, -- you went to
23 Mr. Epstein's house one time and one time only, correct?
24
25
Q.
And I would assume based on what you've
A. No.
In fact, I think you described him as being
A. He was a nice guy. I mean I'm not going to
So clearly, you were not afraid when you
A. No.
All right. And Mr. Epstein didn't offer
A. Correct.
Q.
And that's the only time that you've ever
3
J
HOUSE OVERSIGHT 012269
seen Mr. Epstein?
A. Correct.
3 Q. Okay. And you certainly never called the
police as a result of this?
A. No.
6 Q. And you never contacted the State
Attorney's Office?
A. No.
POUWARAMWO*V0
12
13 0024r ny6A with
14 0#0ggOoOtgg
15 No besides M. which was my best friend.
16 I always talked to her. She asked if I ever wanted to go
17 back again and I told her no. And she was just asking me
18 that as a friend question, not to ask me if I was
19 actually willing to go back over there.
20 Q She wasn't speaking as a representative of
21 Mr. Epstein?
22 A. Right.
23 Q It was just a friend --
24 A. Right, just a friend conversation.
25 Q Okay. Now before you went over there you
.666Nthatftta6W66140NY.
HOUSE OVERSIGHT 012270
sor & Amoco es
Thwlimg and Trasimiptim, rao.
HOUSE OVERSIGHT 012271
sor &A55 ociates
Ropod44mill-eivaivicca,bizi,
Page 17 2
4.44.11C.'m 0!49.11!*4§'*ACP!gA.M.X.W:*iggt
2
3
4 on what your boyfriend had done to you and you wanted to
5 get paid for this massage?
6 A. Correct. He swiped out my bank account and
7 I needed a way to come up with $200 that was over my
8 bank. So I'd get paid 300. I put 200 in my bank and I
9 believe I gave a hundred for taking me.
10 Q. Given your debt situation, it was important
11 to you to convince Mr. Epstein that you were over 18,
12 because you wanted to do this job?
13 A. Correct.
14 Q. Gotcha. Okay.
15 Believe it or not -- let me just check with
16 ms, Sanchez, -- but I think I've got everything covered
17 here.
18 A. I don't believe it was so much Epstein as
19 it was the girls that were working for him, that were
20 bringing in the service, because the girls were the ones
21 telling everybody to lie, to bring in the business so
22 that they could get paid. I know he was traveling them
23 back and forth and renting them rental cars.
24 Q. So I think what you're telling me is that
25 you really believe that Mr. Epstein was relying on what
Q.
Okay. And clearly, you had some debt based
1
1
HOUSE OVERSIGHT 012272
sor & Associates
R*Td Treatudoice, Tap.
Page 18
1 the other girls were doing to make sure that the women
2 that were brought --
3 A. For the most part, yes. I believe that --
4 I mean of course that this is what he wanted and this is
5 what he set up.
6 Q. Uh-huh.
7 A. But I believe he had the girls doing all
8
9
10
11
8
the work for him, so that they were the ones that were
more getting in trouble for bringing in the business than
him.
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19 Q. Correct.
20 Okay. You've understood all the questions
21 I have asked you today, right?
22 A. Yes.
23 Q. Any questions about what I've asked you?
24 A. No.
25 Q - Okay. I really, really appreciate your
HOUSE OVERSIGHT 012273
sor &Associates
llyporting and Travaipfm, hich
Page 19
1 coming in here today. We got this done much quicker than
2 if we had to go to the courthouse to do it.
3 A. Thank you.
4 Q. I didn't coerce you in any way to give any
5 particular answers, did I?
6 A. No.
7 Q. All I asked you to do was tell the absolute
8 truth?
9 A. I'm fine. That's good.
10 Q. And that's what you did, you told the
11 truth?
12 A. Told the truth.
13 MR. GOLDBERGER: thanks so much
14 for coming in today. I appreciaLe it very much.
15 THE WITNESS: No problem.
16 Nis. SANCHEZ: Thank you.
17 (Thereupon, the sworn statement was
18 concluded at 12:15 p.m.)
19
20
22
22
23
24
25
telcutoLtptetbat..c.
3
HOUSE OVERSIGHT 012274
nor 82. Associates
RoporengoadTramiriptipp,MEs.
Page 20
1 THE STATE OF FLORIDA, )
2 COUNTY OF PALM BEACH. )
3
4
5
6
7 of March, 2008 and was duly sworn.
8
9
10 of March, 2008.
14
I, the undersigned authority, certify that
personally appeared before me on the 21st
WITNESS my hand and official seal this 22nd day
Judith F. Consor, FPR
15 Notary Public - State of Florida
16
17
18
19
20
21
22
23
24
25
k.Ria=12M60239.61o.6.0.16.4,31Ali....0.2E1**1.4114,31DiGsedankaa.6.4.051ltiL>bia
HOUSE OVERSIGHT 012275
sor & Associates
Refportimgclit Trommiplion,IED,
Page 21
1
2
CERTIFICATE
The State Of Florida, )
3 County Of Palm Beach. )
4
5 I, Judith F. Consor, Court Reporter and Notary
Public in and for the State of Florida at large, do
6 hereby certify that I was authorized to and did
stenographically report the sworn statement of JENNIFER
7 LADUKE; that a review of the transcript was not
requested; and that the foregoing pages, numbered from 1
8 to 19, inclusive, are a true and correct transcription of
my stenographic notes of said sworn statement.
9
I further certify that said sworn statement
10 was taken at the time and place hereinabove set forth and
that the taking of said sworn statement was commenced and
11 completed as hereinabove set out.
12 I further certify that I am not an attorney or
counsel of any of the parties, nor am I a relative or
13 employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
14 action.
15 The foregoing certification of this transcript
does not apply to any reproduction of the same by any
16 means unless under the direct control and/or direction of
the certifying reporter.
17
18
19
20
21
22
23
24
25
DATED this 22nd day of March, 2008.
arie
Judith F. Consor, Court Reporter
Florida Professional Reporter
HOUSE OVERSIGHT 012276
or & Associates
Uppreagat4Troinawilliva, Int%
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
Parse 22
HOUSE OVERSIGHT 012277
sor & Associates
RopotiNI Trawriggica, /PP.
Page 23
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
HOUSE OVERSIGHT 012278
sor &Associates
RpparIbg Tronwzipliosi, Eti
Page 24
It
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
HOUSE OVERSIGHT 012279
sor 82. Associates
.Roportits. aa4 Tpxygoriptim,Ii
Page 25
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
HOUSE OVERSIGHT 012280
TAB 6
HOUSE OVERSIGHT 012281
2007-04-25 .TXT
1
1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
2 STATE OF FLORIDA
3 STATE OF FLORIDA,
4 vs.
5
JEFFREY EPSTEIN,
6 Defendant.
7
8
9 TRANSCRIPT OF TAPED STATEMENT OF
4-24-07
10
11
12
13
14
15
16
17 Transcribed by:
vicki S. Woodham, Court Reporter
18 Notary Public, State of Florida
Consor & Associates
19 1655 Palm Beach Lakes Boulevard, Suite 500
West Palm Beach, Florida 33401
20 Phone - 561.682.0905
21
22
23
24
25
Page 1
HOUSE OVERSIGHT 012282
2007-04-25 TXT
2
1 (Taped statement as follows:)
2 AGENT RICHARDS: This is Special Agent Jason
3 Richards with the FBI along with Special Agent
4 Nesbit Kirkendul and Assistant United States
5 Attorney Marie Bilafonia here to conduct an
6 interview with Ms. Also present is
7 her attorney, Jim Eisenberg and Carrie Sheehan.
8 MR. EISENBERG: And we are here -- This is Jim
9 Eisenberg and my investigator, Ms. Sheehan is here.
10 And we're here pursuant to a subpoena that was
11 served on me for and that's why we're
12 here. So Ms. Bilafonia, it's your show.
13 MS. BILAFONIA: Okay, great.
14 AGENT RICHARDS: I also want to add that the
15 date is 4-24-07, and the time by my watch is 4:21
16 p.m.
17 BY AGENT RICHARDS:
18 Q. we just want to start off and I'll lead
19 off first. We just want to get some basic info about
20 you, simple stuff. I've got your date of birth as
21 is that correct?
22 A. Yes, sir.
23 Q. I just want to get like your basics like that
24 stuff first. Your current address?
25 A.
Page 2
HOUSE OVERSIGHT 012283
2007-04-25 TxT
3
1
2 Q. You have a cell phone or --
3 A.
4 Q. And home phone?
5 A. Only cell.
6 Q. Only cell, okay. Now have you had other cell
7 phone numbers in the past and do you know any of those?
8 A. that's the only one I can remember.
9 Q. Okay. But you had some others?
10 A. Uh-huh.
11 Q. Okay.
12 BY MS. BILAFONIA:
13 Q. Who's your service provider?
14 A. Metro.
15 Q. metro. And for that other number as well?
16 A. Yes.
17 BY AGENT RICHARDS:
18 Q. Where did you go to high school?
19 A.
20 Q. And what year did you graduate?
21 A.
22 Q. What year was that that you dropped out, do you
23 remember?
24 A. No.
25 Q. What year were you supposed to graduate, your
Page 3
HOUSE OVERSIGHT 012284
2007-04-25 .TXT
4
1 class?
2 A.
3 Q. Okay.
4 A. I had got my GED.
5 Q. when did you get that?
6 A. About three months ago.
7 Q. And are you going to college anywhere
8 currently?
9 A. Not right now.
10 Q. Plans?
11 A. i have plans.
12 BY MS. BILAFONIA:
13 Q. Where are you thinking about going?
14 A. I'm not positive what I want to do. There's a
15 lot of things on my mind, but right now I'm focusing on
16 my son. I have a two year old so right now I'm just
17 working.
18 AGENT RICHARDS: He's a handful?
19 THE WITNESS: Yeah.
20 AGENT RICHARDS: I have one, too.
21 THE WITNESS: Yeah. So in the future, I'm
22 definitely going to go to college. I'm going
23 definitely going to go to school. But I have, you
24 know, a modeling career going on right now that's
Page 4
HOUSE OVERSIGHT 012285
2007-04-25 TXT
25 hopefully going to -- some of you will notice me,
5
1 hopefully, and that would be great, but i don't
2 know.
3 BY MS. BILAFONIA:
4 Q. Where else are you working?
A. I work for Advanced cleaning systems. They
6 clean carpets.
7 AGENT RICHARDS: Advanced what was it?
8 THE WITNESS: System Cleaning.
9 BY MS. BILAFONIA:
10 Q. And where are they located?
11 A. Las Palmas, 11 Swanee, S-w-a-n-e-e, Swanee
12 Drive.
13 Q. Are you working in an office there or do you go
14 out to people's homes?
15 A. I work in an office there.
16 BY AGENT RICHARDS:
17 Q. Obviously, you know why we're here and what we
18 want to talk about. so let me just kind of lead into do
19 you know Jeffrey Epstein?
20 A. Yes.
21 Q. Yes, of course, you do. Now when did you meet
22 Jeff? Does he go by Jeff or Jeffrey or --
23 A. Jeffrey.
Page 5
HOUSE OVERSIGHT 012286
2007-04-25 .TXT
24 Q. okay. When did you meet him and who introduced
25 you to Jeffrey?
6
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
A.
JeffreY-
Q.
My girlfriend
Do you know her last name?
oduceci me to
A. No. she was a friend of one of my friends, so
really didn't know her.
BY MS. BILAFONIA:
Q •
when was that?
A. I really couldn't tell you. I don't even
remember. It's been so long ago.
BY AGENT RICHARDS:
Q. So introduced you to him. Was it at a
party setting or how did you guys meet?
A. No. She came to me and she said hey, would you
like to make a couple dollars and I said sure. I said
doing what? She said, Well, I know this Jeffrey. He
lives on Palm Beach Island and I bring girls there and he
likes massages and I was like okay. So I asked her, I
said well, what about my age? And sh said well, juct
].:64
gAh4X,
4.10#4
fake ID
.. -.0!aloin„
th8re.
Q. Okay. And about what time period was it that
Page 6
HOUSE OVERSIGHT 012287
2007-04-25 TXT
22 you went over there first, do you remember?
23 A. What time period?
24 Q. Yes. As far as what year was that that you
25 were in school?
7
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
A. I was 16
Q. Sixteen.
BY MS. BILAFONIA:
Q. Were you a freshman or a sophomore, do you
remember?
A. I couldn't tell you. I couldn't tell you.
Probably a sophomore.
Q. Now you said that...
Awl-0104440g Did she elaborate on
massages?
ld 001#05
what types of
sometimes he likes topless masges,
ave to do anything you don't wan
1§i
Q. And do you know whether
massages?
A. Yeah, she said she's done it before.
Q. And do you know whether had taken any
other girls over to see Jeffrey?
A. Yes, she probably did.
Q. Did she tell how much you would make?
Page 7
had given him
HOUSE OVERSIGHT 012288
2007-04-25 IIIIII[TxT
21 A. Yes.
22 Q. what did she tell you?
23 A. We go there and we make $200 in 30 minutes.
24 Q. Now you said that you asked her, you know, what
25 do i need to be worried about my age. whsodficioagz
8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
A. Because I don't want to be -- you know, it was
like I was underage and I was young and I was pretty
stupid and I didn't want to get -- I didn't
in trouble, so.. I alwaysA4010&
aroma
e.
atE
want to get
make
14:004*.i.7
ecause,
6AW
BY AGENT AGENT RICHARDS:
Q. Now did she --
at? In school? What setting?
A. I wa at a frinif
whe
04.0100 m
girlfriend's
house. I don't know what girlfriend's house it was.
Everybody was just hanging out. And she said -- she came
up to me and she asked me. She said, do you want to make
a couple bucks and I said sure.
Q- 40 Aft0t8
there to meet r 40.4#
Page 8
e. took .you over,;
u again
HOUSE OVERSIGHT 012289
set up any appointments with him.. or anything--1-1.4r.: that?'
o, I gave 3ffrey mynumbertime you want me to give you a massage again, than welcome to.
9
1 BY MS. BILAFONIA:
2 Q. So took you that first time, but then
3 after that you communicated directly with Jeffrey?
4 A. uh-huh.
5 Q. Tell us about that first time that you went to
6 his house. Who -- how did you get there?
7 A. one of 11111111s friends and they dropped us
8 off and then we went. You know, we got escorted up to
9 the massage room and he told me everything. He said,
10 Listen, I like massages. And we had the whole massage
11 table laid out, the lotions and everything. And she was
12 in there for the first like five minutes. And the first
13 time I gave him a massage, she left the room and I gave
14 him a massage. And she told me, she says he likes women
15 topless massages. so I willingly the first time took off
16 my top when I gave him a massage and nothing more than
17 that. og Hffiaiihie
Page 9
HOUSE OVERSIGHT 012290
2007-04-25
18 was out of there.
19 Q. Okay. Let me just ask you a couple of
20 follow-up questions. You said that someone escorted you
21 up to the room. Do you know who that was?
22 A. one of -- what's her name? Actually,
23 just said, you know, it's up there and she just told
24 me where it was.
25 Q. And then you said that you and went
10
1 upstairs together?
2 A. Uh-huh.
3 Q. And stayed in there for the first few
4 minutes?
5
6
7
8
9
10 the room or did he come in after you were already there?
11 A. iWW4 ri  the room al ready
12 Q. And you said that you took your top off. Did
13 anybody ask you to take it off, like did say it's
14 time for you to take it off?
15 A. No, she wasn't in the room.
Page 10
A. Uh-huh.
Q. Was Jeffrey already in the room by the time
•left?
A. Yeah, he was in the room.
Q. Okay. Was he there when you guys showed up in
HOUSE OVERSIGHT 012291
2007-04-25 TXT
16 Q.
17
18
19
20
21
22 that
23
24
25 his massage?
A.
By the time you took it off, okay.
salci, T told;Jeffrey:
massages topless.:. And hes *,7r
0flrt h4Oomv
46046
...............
w.
-01
Q.
ing1Y
O.:
okay. And during that first massage, you said
you gave him a shoulder and neck massage?
A ick back shou1der Otik
Q. was he face down the entire time that he got
11
1 A. Yeah.
2 Q. And what did you do during the massage? Did
3 you talk or --
4 A. Yeah, we talked.
5 Q. And what would you talk about with him?
6 A. Well, we were just getting to know each other.
7 we talked about how my lifestyle was, what he did for a
8 living and just all positive things, really nice things.
9 Q. okay. what was he wearing when you first came
10 in the room?
11 A. I'm sorry. When he first -- when he first came
12 in the room, he was fully clothed. And then he said, you
13 know, wait a second. I'm going to go on the massage
14 table and he put a towel over him just like a normal
Page 11
HOUSE OVERSIGHT 012292
15
16
17
18
19
20
21
22
23
24
25 massage or after the massage he gave you?
2007-04-25 TXT
masseuse would do.
Q. Did he undress and put a towel around him?
A. uh-huh.
Okay.
VOOMifOiranyrttng it as
Q.
A.
neck and shoulders.
Q. And after the massage was over, you received
the $200?
A. He gives money right away.
Q. I'm sorry. Was that before you started the
12
1 A. The first time, he gave me the money right
2 away.
3 Q. Okay. And he's the person that paid you the
4 $200?
5 A. No, it's always
6 Q. gave you the money?
7 A. Uh-huh.
8 BY AGENT RICHARDS:
9 Q. What's 's last name, do you know?
10 A. I don't know.
11 MR. EISENBERG: You can't look at papers. If
12 you think you know, you know. If you don't know, --
Page 12
HOUSE OVERSIGHT 012293
2007-04-25111111ITXT
13 THE WITNESS: No, I don't know. I don't know
14 's last name. He does.
15 BY MS. BILAFONIA:
16 Q. Okay. The only thing I'm confused about is you
17 said that didn't even take you upstairs. She just
18 told you where you should go?
19 A. Uh-huh.
20 Q. So when did she pay you the money?
21 A. She paid me then and there when I first walked
22 in the door, me and
23 BY AGENT. RICHARDS:
24 Q. She paid you before you went upstairs?
25 A. Yes.
13
1 BY MS. BILAFONIA:
2 Q. And how much was paid?
3 A. Everybody got paid $200.
4 Q. And after -- So after the massage was finished,
5 you said that you had already been paid. Who asked you
6 for your name and telephone number?
7
A. Jeffrey said, well, I'd like to see you again.
8 Can I have your number? From what I remember, I'm pretty
9 sure he asked me for my number and I gave him my number.
10 Q. Okay.
11 BY AGENT RICHARDS:
Page 13
HOUSE OVERSIGHT 012294
2007-04-25 TXT
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q.
Did he write it down upstairs? He had a pen
handy, I hope?
A. uh-huh.
BY MS. BILAFONIA:
Q.
On that first massage, you said that you worked
on him topless. But when you first started, did you take
-- what were you wearing?
A.
3R4PW
I was wearing og
massages.
noñiial shirt
assagearid
And, of course, h•
6000P P' And he's like yeah, I do i prefer
that. And who wouldn't, you know? so i said okay and I
took it off.
Q. And you took off your bra as well?
1 A. Yes.
2 Q. And you left your jeans on?
3 A. Yes.
4 Q. okay.SQ gave hr
5
6 A.
7 Q.
8 A.
9
jpgapgplaIng
yer:
the Massag
Q. So you said that that day you gave your name
Page 14
14
HOUSE OVERSIGHT 012295
2007-04-25 IXT
10 and number to Jeffrey. When was your next contact from
11 him or anybody who worked for him?
12 A. The next day, he had called me and he said
13 would like to come out again and I'd like to see you
14 again. I said sure. I took a taxi there and I went
15 there again.
16
17
18 Q. Okay. MENCOMANVOMOOFis the pmrsor
19 who called you for that appointrnent,,
20 A. No, 1000W
21 called me From what I remember,M4.044fItig41110
22 4WW
23 Q. okay. And she said Jeffrey says he wants to
Q. The following day?
A. The next day.
24 see you again?
25 A. Yes.
00414.0
15
1 Q. And then you said you took a taxi?
2 A. Yes.
3 Q. Is that how you would normally get to and from
4 his house?
5 A. uh-huh, if I didn't have friends because I
6 don't drive, yeah.
7 BY AGENT RICHARDS:
8 Q. How did you get home the first time when
Page 15
HOUSE OVERSIGHT 012296
A. No, no. t:iiii4614k4aliiiii
paid for my own taxi.
Q.
2007-04-25 =.1-x-r
9 took you over? Did she get a taxi?
10 A. No, our friend came back and picked us up.
11 Q. which friend was that?
12 A. His name was Brian. I don't know his last
13 name. I really didn't know and I didn't know her
14 friends or whatever, but I met Jeffrey. And once I met
15 Jeffrey, he was a very awesome guy and I just -- I don't
16 know. I ended up giving him my number so I could --
17 didn't want or Brian to drive me anymore.
18 would rather go to him on my own.
19 BY MS. BILAFONIA:
20 Q. When you would take the taxis to and from,
21 would he pay for them?
22 A. uh-huh.
23 Q. And he would pay when you arrived?
24 A. uh-huh.
25 Q. And then he would just give you extra money
16
1 when you left to pay for the taxi?
2
3
4
5 the massage?
6 A. TWO hundred, yeah.
Page 16
:ram.cmg:
okay. so from the money that he paid you for
HOUSE OVERSIGHT 012297
2007-04-25 .TXT
7 Q. Where were you living at the time?
8 A. I was living at It's
9 located on So I would take, you know,
10 straight down to where I lived.
11 Q. Do you remember about how much that taxi fare
12 was each way?
13 A. Twenty dollars.
14 Q. And did you always use the same taxi service
15 or --
16 A. No, I used different taxis all the time, so --
17 Q. And you would just call and have them come to
18 your house?
19 A. Uh-huh. I used a whole bunch of different
20 taxis, whatever is available.
21 Q. So you mentioned that the second massage, was
22 it any different than the first one?
23 A. Yes.
24 Q. How was it different?
25 A. When I went there, I went there by myself. And
17
1 I went up to the massage room and Jeffrey was just like
2 regular like he was before on his stomach and he had a
3 towel over and we started the massage and
4 off willinoly And after the massage, 11.9409.
5
you c.omfo.rtabl'
Page 17
HOUSE OVERSIGHT 012298
6 this an I Said
7
8
9
10
11
12
13
14
2007-04-25
he turned anuun
d. And this was
like at the end of the massage, our 30-minutes massage,
usually it was even shorter than that. And he
masturbated at the end of the massage and it was like two
seconds and I was just topless.
Q. And when he turned over, the.n did he touchfie.0
at al or was he just --
A- W i didE#020405Ehim. He dd not touch AC
He didn't even want
15 Q.
16 *OEMO
17 A.
18 Q.
19 A.
20 *0401:
21
22
23
24
25
Q.
nipples during the massage?
A. Actually, later on -- because I saw him for a
long time. Later on, I asked him, you know, and I asked
him -- I would give him -- you know, I would rub his
You didn't like continue the massage while he
yokaileW4OSIMOOT
okay. I cut you off. You said he didn't even?
He didntt want me to touch hi
idn*t
Did he ever ask you to rub his chest or rub his
1 chest or whatever and massa
2 masturba
3 Q.
Ida
so eventually you would continue the massage
Page 18
18
HOUSE OVERSIGHT 012299
2007-04-25111111TxT
4 and he would masturbate at the same time?
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A. Yeah, but it wasn't on his lower area.
Q. No, you never touched his penis?
A. Rig
Q.
You were paid $200 again?
A. Always.
Q. Always? Every time you went there?
A. Always.
BY AGENT RICHARDS:
Q. was it always that paid you?
A. Sometimes Jeffrey would and sometimes
would.
BY MS. BILAFONIA:
okay. So that was during the second massage.
Q. Was it usually before or after the massage?
A. After the first time, it was always after.
would go downstairs and I'd get paid.
Q. So just sort of tell us, when a massage ended,
which
assume was after
A. It WaSn'
Q. Okay.
A. It wasn't like
he
ejaculated?
hough,
every time we went there he
2 sometimes he.just wanted..back masage.
19
HOUSE OVERSIGHT 012300
2007-04-25 TXT
3 Q.
4
okay. But when the massage was over however it
ended, you would just get dressed and go downstairs by
5 yourself or did take you downstairs?
6 A.
7 great.
8 with us
9 WWWAII
10
11
12 A.
13 you.
14
15 or more than once a week?
16 A. Yeah.
17 Q.
18 A.
19
20
21
22
23
24
25
More than once a week?
Personally woo
Q. Okay.
gave Jeffrey?
Yeah. The chef would make us food and it'd be
And Jeffrey would get dressed and he'd come down
sometimes or, you know, it wasn't -- we had fun.
OW
How many massages do you think that you
reY a 1 massages.
saw him
0:00041W4E,
can't tell
Q. And how many times -- would you see him weekly
d bring girl
S.
Q. okay. But either you would or either a girl
that you brought?
A. Yeah, uh-huh.
Q. Okay.
A. But after a while, it wasn't me anymore. I had
brought girls, but I got paid $200 to bring girls.
Q. Okay. So let's talk just about when you were
Page 20
20
HOUSE OVERSIGHT 012301
1
2
3 his feet massaged.
4 massage sessions?
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q.
14 Off .. . .
e:
ikithf.64Z t0440.0$61'
t440
iked back massages. Sometimes he
ssages.
h cf
s ea massage a
2007-04-25 Il.TXT
performing the massages. what other sorts of things
would happen? You said that sometimes he would just like
Sometimes he likc.•his head massage&
massages And it wasn't ever
there he iisturbated.'
Q. Okay. Ally idea
th e th sturbate
sgat6ti
astur a
cf
ways perfo
less . , . . .
Id you eve
I.
get comPl etel
A.
Q.
A.
ot ing?
Willinqiy. one time
ing jOkes an rYtni and: wi:flin
otally nude, hut r was fine
Okay.
Totally fine with it.
And how did that massage go?
Actually, 'it was a foot massa
Page 21
HOUSE OVERSIGHT 012302
2007-04-25 TXT
21
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
-00f64-!,,  4go.r.1114, *041i400A0N1140AW0400
Q.
And how much were you paid for that?
A. Two hundred every single time.
DOV4144640$0040100Vtouch4004-Wot
4t0g00#10004060g
Q.
A. Never, never.
Okay.
Q.
BY AGENT RICHARDS:
Q. why not?
A. Why not? Why would he?
Q. You seem like a nice young lady, attractive.
He never had any urges to --
A. I asked him, I said, when are you going to get
married? when are you going to get married, Jeffrey? He
said, I'm never getting married. He has, you know,
beautiful women all the time. why would he -- no,
huh-uh.
BY MS. BILAFONIA:
1-M-110).Mr1P41I04400
y4yRi:
Q.
v4iWO
.w400046.4i4E
Okay. Now you said that at some point you
ven
started bringing other girls over?
Page 22
WAT
erx nP ever.
HOUSE OVERSIGHT 012303
We just,
A-
toPless massages.
2007-04-25 TxT
22
1 A. uh-huh.
2 Q. How did that start?
3 A. He likes to see different faces.
4 Q. So he asked you if you had friends that
5 could bring over or other girls?
6 A.
7
8 0000Ott
uh-huh.
you
9 A. All of90.-000i100100 if.
10 fia
b0.650300W100
11 ii6t4WWWWW6405fft6e6244466W444
12
13
14
15
16
17
18
19
20
21
22
23 Q. And did any of them tell you what happened
24 after that?
25 A. Always, always, I even asked them.
0040, know 1
iris OWIROC
es massages,
u ,re not corn 0
r-
013or
Oft
make sure
°use?
Page 23
giV;
HOUSE OVERSIGHT 012304
2007-04-25 TXT
23
1
2
3
4
5
6
7
Q. Okay. And with the other girls, was it the
same as what you did or different?
A. Yeah, yeah. I mean, well, I was more willingly
to do more, you know. Like I said,
one t'me But the o
.Lop.l es
d that's al
14,11t •nu
they Practical
osOk6kW11041t4A0g
Some girls
n't want to
3effrey didn't
8 OallT,X
9 Q. Were there girls that you brought back multiple
10 times?
11 A. A couple, a couple, but he really liked to see
12 different faces.
13 Q. okay. I'm just wondering are there some girls
14 he really liked and others he didn't like or did he have
15 any preferences in terms of blondes, brunettes?
16 A. He liked girls like me.
17 Q. Okay. Thin and attractive?
18 A. I guess. Yeah, very attractive women. And he
19 thdnt say girls He said women all th ttme
20 Q. Did you ever bring anybody he didn't care for?
21 A. Huh-uh.
22 Q. Yeah?
23 A. Yeah.
24 Q. How was she different than the others?
25 A. Black. I screwed up.
Page 24
HOUSE OVERSIGHT 012305
2007-04-25 TXT
24
1 Q. How did you know you screwed up?
2 A. He doesn't like black women, obviously.
3 Q. So he let you know? He told you that?
4 A. Yeah, but he was still nice and he still gave
5 her her 200 even though he didn't even have a massage by
6 her.
7 Q. How did he -- he paid you $200 for bringing
8 each girl?
9 A. uh-huh.
10 Q. And when he told you that, 1 mean, that's what
11 he told you that he would pay you $200 for bringing the
12 girls?
13 A. Yeah. He said if you bring me -- if you bring
14 me girls, ill definitely, you know, give you money,
15 compensate you for your time and willing to do that for
16 me, yeah.
17 Q. And you said at that point you stopped
18 performing massages for him?
19 A. At that point, 1 didn't -- it would be
20 sporadically like. Usually, 1 had so many girlfriends at
21 the time that, you know, there were some new faces to be
22 saw. And if no one was available, then would go.
23 Q. 1 got you.
24 A. So --
25 Q. Do you know some of the girls that you brought,
Page 25
HOUSE OVERSIGHT 012306
2007-04-25 =.-Da-
25
1 some of the their names?
2
3
4
A.
don't remember, really. They were like not
even friends. They were just associates, you }mow. if
'lends of friends, Sc
5 Q. we have -- I don't know. We have some messages
6 I guess that some girls' names that would call Jeffrey
7 and leave a massage. There's some girls names that are
8 referenced. we were just wondering if you knew them?
9 A. If you name them, I can probably remember.
10 MS. BILAFONIA: Jason, do you have that?
11 BY AGENT RICHARDS:
12 Q. is one.
13 A. I don't know Do you know her last
14 name?
15 MS. BILAFONIA: We were hoping you did.
16 THE WITNESS: No, I don't.
17 BY AGENT RICHARDS:
18 Q.
19 A. No, that sounds like a black girl's
20 name.
21 Q. Well, you brought a black girl. what was her
22 name?
23 A. I don't know. Don't ask me.
24 Q.
Page 26
HOUSE OVERSIGHT 012307
2007-04-25 TXT
25 A. yeah, i brought
26
1
2
3
4
5
6
7
8
9
10 Rbbie
11 MW0A4A_A
12
13
14
15 Q.
16
17
18
19
20
21
22
23
Q. Who is she? Tell us about
A. sabrina, we look just alike, if that's the girl
I'm thinking about. we went to school together and I
brought her one time and then she ended up moving so she
couldn't come with me.
Q. were you guys in the same grade or --
A. No, she was older than me.
A year or two?
A.Actually, •
don't
e was like, you know two ranks.
Q.
Q.
So when you were a sophomore, she was a senior?
A. i just met her in school and I told her.
BY MS. BILAFONIA:
what was her last name?
A. I don't know.
BY AGENT RICHARDS:
Q. Do you know where she lived? A. I just
met her in school and I told her about it.
Q. YOU told her about it at school? Is that where
your discussion was or --
A. Well, I said give me your number. I said you
can make a couple of dollars. It's real easy. And if
Page 27
HOUSE OVERSIGHT 012308
2007-04-25 .TXT
24 you're comfortable with it, give me a call.
25 Q. Was that at'Lklikier6ei4Faa
27
1 A.No, t school
2 Q. At school. You're not sure what her last name
3 was?
4 A. I have no idea.
5 Q. Do you know where she lived or anything like
6 that, what car she drove?
7 A. No.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Q. what'd she look like?
A. What she looked like?
Q. Yeah.
A. Like me, everything, •
. (Start Side B of tape.)
AGENT RICHARDS:
hair, eyes.
Time recorder is being
restarted is approximately 4:50 p.m
BY MS. BILAFONIA:
Q. We were talking about You were at
at the time?
A. No, I was at
Q.
okay.
A. And that's where went to school.
Q. what about a girl namedM?
Page 28
HOUSE OVERSIGHT 012309
22
23
24
25
A.
BY AGENT RICHARDS:
Q.
A.
2007-04-25
who?
Did you bring a
.4000,1*
TXT
28
1 Q. I want to know about every one you brought.
2 A. well, one of them died recently, so --
3 Q. What was her name? In a car accident or
4 something?
5 A. No, she died. unfortunately, she got shot in
6 the head. You guys probably heard it on the news. She
7 got shot in the head by this guy. I don't want to even
8 talk about it because I'll cry.
9 BY MS. BILAFONIA:
10 Q. Let's talk about the other
11 A. I don't even know. T don't know. I don't
12 know. There were some girls that just I would take one
13 time and then I would never talk to again, so i don't
14 know.
15 Q. How many girls do you think you brought to
16 Jeffrey's house?
17 A. That's a good question. I bring a lot, like
18 maybe -- I don't know, maybe 30, maybe 30. It was all
19 about the money to me at that time.
20 Q. Now any of the girls that you brought, did any
Page 29
HOUSE OVERSIGHT 012310
2007-04-251111111TxT
21
22
23 go through you?
24
25
A. They w
Q. So you don't know?
of them leave their names and numbers and then they would
get appointments directly from Jeffrey or did they always
60004IT
29
1 BY AGENT RICHARDS:
2 Q. You weren't getting paid, right?
3 A. I told them, I said, Don't give him your
4 number.
5 BY MS. BILAFONIA:
6 Q. If you brought the same girl more than once,
7 would you get paid each time you brought them or just get
8 the initial $200?
9 A. Every single time I brought a girl, okay, or I
10   referred a girl, I always got $200, always.
11   Q.   Even if she came a second time?
12   A.   Yes.
13   Q.   You would get $200 every time she came?
14   A.   Yes.
15   Q.   Good deal. Okay. What about?
16   A.   who?
17   Q.   Any that you brought to Mr. Epstein's
18   house.
Page 30
HOUSE OVERSIGHT 012311
9
10
11
12
13
14
15
16
17
2007-04-25 TXT
19 A. 1 brought a
20 Q. Where did she go to school?
21 A. she didn't go to school.
22 Q. okay. How did you know
23 A. been my -- she's my friend in the
24 past. How did I meet at a party or she was my
25 -- Actually, she was my baby's father's girlfriend at the
30
1 time and 40i1M:
2 Q. You asked her if she'd be willing to go to
3 Jeffrey's house?
4 A. uh-huh.
5 Q. And when -- do you remember when that would
6 have been?
7 A. Actually, a couple weeks, a couple weeks. I do
8 remember her. A couple weeks after I met him.
Q. so you brought her pretty soon after you met
Jeffrey?
that
A.
Q.
A.
Q.
A.
Q.
the
uh -huh.
Seventeen.And how old was
-.—.
And what happened when you brought
The same thing.
Okay. Well, I know that sometimes you said
girls would tell you what happened?
Page 31
HOUSE OVERSIGHT 012312
18
19
20
21
22
23
24
25
2007-04-25 TXT
A. She went in there. She had a massage -- she
gave a massage on his back. she went a couple times. He
liked her. She went a couple times.
-0114g:A
tI4MW.4:
„:04.agg And then she went, I think, like two
times after that. And yeah, he masturbated, but no
touching. She didn't -- there's no touching of him. No
1 touching of her.
2 *1509MCMAG
3 tiofl
4
rspec-
5 *RONALwe wc
6 about it
7
8
9
10
11 call a taxi.
12
13
14
15 Q.
31
Problem and
h Y'd 119 me) YoU know,•for us to go to
Q. HOW would -- how would you make appointments
for girls to go over there?
A. I'd call them and they'd say hi, do you want to
go to Jeffrey's house? And they'd say yes or no and we'd
Q. How would you know when Jeffrey was going to be
in town?
A. when /KM 11
Did she always call when they were already in
Page 32
HOUSE OVERSIGHT 012313
A. well, I'd tell them, I'd say
-- well, I mean,
He'd have
2007-04-25 TXT
16 town or would she -- how far in advance would she call
17 you?
18 A.
19 Beach They never called me from anywhere They've
20 never called me from anywhere else. It was always when
21 was in Palm Beach. They'd say hi, we're down here. If
22 you want to come and see Jeffrey, you're more than
23 welcome to.
24 Q. So you wouldn't have like a specific time when
25 you would go over, like be here at 11 or be here at two?
1
2 I'd have to work around his schedule.
3 around mine. Yeah, we'd e there
4 11
5
6
7
8
9
10 chef would answer the phone. HiS maid would answer the
11 phone. That's --
12 Q. But was the only one you talked to about
13 making appointments?
14 A. uh-huh, yeah. well, yeah, if Jeffrey wasn't
Page 33
-i-hey only liT4*::0C01i0h:gtti4 .. . , were in Palm
be there
atever,
to
32
work
Q. no you -- I know that you said you talked to
on the phone. was there anybody else that you would
talk to on the phone?
A. If Jeffrey wasn't there like if I'd call him to
see how he was doing or whatever, you know, he had -- his
HOUSE OVERSIGHT 012314
2007-04-25IIIIIIITXT
15 available, they'd, you know, he said, the chef or you
16 know, whoever, said Jeffrey will get back to you. Yeah,
17 =L made the appointments.
18 Q. So when you were calling to talk to Jeffrey,
19 you were calling the house phone over in Palm Beach?
20 A. Uh-huh, yeah.
21 Q. And how often would you talk to Jeffrey on the
22 phone as opposed to talking to one of his assistants?
23 A. Me and Jeffrey hardly ever talked on the phone.
24 He was always busy. It was mostly We'd talk when
25 I would get there, you know. So it was like hey, do you
33
1 want to come in? Yes, cool, you know. Come there, no,
2 cool, bye.
3 Q. Do you know someone who works for Jeffrey named
4 ?
5 A. I think I met her one time.
6 Q. And what do you know about her?
7 A. She was there. And the person , 1 think,
8 I'm not positive, okay. I'm pretty sure she said that
9 she's from New York and she travels with Jeffrey, but I
10 think I met her one time, if that's the girl that rings
11 the bell, you know, in my head. Nadia I think is that
12 one person I met one time.
Page 34
HOUSE OVERSIGHT 012315
13
14
15 have a girlfriend or a steady?
16
17
18 girlfriend.
19 Q.
20
21 other than Jeffrey?
22 A. NO.
23 Q.
24
25
2007-04-25=11TXT
Q. Now you said that you a teased Jeffrey about
whether he was getting married. Did you ever know him to
A. No, he told me he's never been married. He's
never had a girlfriend and he doesn't want to have a
ave
A-AWAVOiOaii&
Im#000t
A. 19.0.k.xiA0611=:.,Siii0A0A0E11#0.0.1.0#00
once or twice, not thatIO#00
Were you ever asked to bring a girl for someone
else like to give a massage to somebody else or to anyone
-mtwire
34
1 Q. But anybody else, either any friends that were
2 in town or --
3 A. No. See, my mother is a masseuse and I have
4 experience massaging and he always liked my massages. So
5 he told about my massages and she said, yeah, I want
6 a massage so I'd go over there. I think it was one or
7 two times and I gave her a massage.
8 Q. NOW when the girls were upstairs with Jeffrey
9 in the bedroom, what would you do?
10 A. The chef would make me carved tomatoes, put
11 some crab meat in it and I'd just eat, wine and dine. It
Page 35
HOUSE OVERSIGHT 012316
2007-04-25 .TXT
12 was wonderful, great.
13 Q. And when you would talk to the chef --
14 A. Yes.
15 Q. -- would anybody else from the house be there?
16 A. Yes. I don't know their names. I can't
17 remember. There were like all these foreign girls from
18 -- like they're beautiful, beautiful models that are from
19 different -- they have accents. And no, but it was real
20 interesting because we'd talk. And, you know, I'd learn
21 a lot from them and they'd learn a lot from me just being
22 American. And no, every time I went there it was a good
23 time. 414 .t, 404IWiut atC! 0 arid swum or
24 'gwohjAt.,
25 Q. And how long you would the other girl be
ar the Po
35
1 upstairs normally?
2 A. Twenty, 25, 20 to 30 minutes.
3 BY AGENT RICHARDS:
4 Q. Back to is there anything else
5 about her that you can remember? You were friends with
6 her. She went three times, you think? Did she go back
7 without going through you to set up any appointments that
8 you know about?
9 A. I don't know.
Page 36
HOUSE OVERSIGHT 012317
2007-04-25
10 Q. Okay. Were there any othe1111111111that you
11 brought? 1 know you brought other or multiple
12 Britanys.
13 A. Yeah. I don't know. If you would say like a
14 last name, then I would probably remember, but I don't.
15 Q. Any 111111 Did you bring a=?
16 A. , yeah, that sounds familiar. Yeah,
17 yeah.
18 Q. IIIIIIIIIIIW
19 A. Uh-huh.
20 Q. What can you tell me about her? How old was
21 she?
22 A. She's older than me.
23 Q. Do you know her from school or --
24 A. No. where did 1 meet her? 1 met her in my
25 neighborhood and I asked her if she wanted to go and
36
1 yeah,M. She was only there one time, though.
2 Q. Did she tell you how it went with him upstairs?
3 A. Yeah.
4 Q. What'd she say?
5 A. She said -- she's like ah, 1 don't know.
6 Q. She freaked out or something?
7 A. NO, no, but he didn't want her again. He likes
8 tall, slender and she was like short.
Page 37
HOUSE OVERSIGHT 012318
2007-04-25 .TXT
9 Q. what did she say about him?
10 A. she had fun.
11 Q. She had fun?
12 A. Uh-huh.
13 Q. What did she say happened up there?
14 A.
15
16 BY MS. BILAFONIA:
17 Q. Did you ever, either when you gave him a
18 massage or any of the girls, did you ever use a big back
19 massager or it was only manual massage?
20 A. No, it was only my hands. we never used
21 anything else.
22 Q. Now when you were working for him, when you
23 were going over to Jeffrey's house to give massages, did
she as topless a
just gave masse.
climax or anything
24 you have a boyfriend?
25 A. Yeah, yeah.
1 Q. Okay. How did he feel about you going to
2 Jeffrey's house?
3 A. He was a jealous little boy, but he didn't
4 care. Bring home the bacon.
5 Q. what's your boyfriends?
6 A.
Page 38
37
HOUSE OVERSIGHT 012319
7
8
9
10
11
12
13
14
15
16 what you were doing at Jeffrey's house?
17
18
19
20
21
22
23
24
25
2007-04-25 .TXT
Q. Now I know you that you mentioned that you had
a baby. Is that the baby's father?
A. No, no, thank God.
Q. who is the baby's father?
A.
Q. Okay, And were you still going
to Jeffrey's when you were pregnant?
A. I would bring girls there when I was pregnant.
Q.
So did -- kit.0
A. ....... 4*
04000kabout
Jeffrey actually threw me my baby shower and he got me
furniture and a nice rattle for my son and just really
nice things, I love mommy frames.
Q.
Was the shower at his house and did he attend?
A. No, no, at my house, at my house. And no,
Jeffrey wasn't there. He just sent to bring me
gifts for the baby.
Q. oh, okay.
1 BY AGENT RICHARDS:
2 Q. Did ever go over there with you?
3 A. No.
4 Q. He stayed away.
5 A. No, he didn't go, no.
Page 39
38
HOUSE OVERSIGHT 012320
2007-04-25 TXT
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
1
BY MS. BILAFONIA:
Q. Did Jeffrey ask you about boyfriends? I mean,
was he curious about --
A. Yeah, we always talked about everything, yeah.
DO you have a boyfriend, yeah, no, you know. We talked
like friends. I don't know. Just about our life
stories. You know, he probably knows my whole life
story.
BY AGENT RICHARDS:
Q. NOW do you still have contact with him or --
A. who?
Q. Jeffrey.
A. No, no one's allowing me.
BY MS. BILAFONIA:
Did he:
YgO
WOOIO to be400-dilr
were aspiring to be?
16 at
e and
2 can
3 Yor
- 11
ry
40WII-141AieWOOW
wanted to
you aria bring you
.!96ititlit.iiC)).#004Wit..0i;!!!lbadg#1.0.01- there, but c!!.
Page 40
39
HOUSE OVERSIGHT 012321
scre
2007-04-25 TXT
always turned it down because I was 16 and 1........cii
5 that to get OLIt-
6 Q. What did you say to him? How did you put him
7 off?
8 A. I don't know. oh, well, I don't know. No, he
9 wasn't like begging me or anything. He asked me a couple
10 times and i said -- i just -- there was like no say about
11 it. I just -- I didn't go. And it wasn't like he asked
12 me all the time. He just it's a couple times he asked.
13 He said I'll bring you to New York or whatever we do and
14 we can, you know, try to fulfill your dreams, b
15 WNW Ardat IS50010460 44ANCA
16
17
18 any way? i mean, did he tell you if you want to be a
19 model, you know, this is going to mess with your chances
20 as a model or offer any --
21 A. No.
22 Q. I'm wondering like how much was he giving you
23 advice? How much stuff were you really -- what did you
24 talk about?
25 A. After the baby, we didn't really even talk.
th
APR.*
Q. Did -- when you got pregnant, did he react in
40
1 was -- I was totally -- I changed. YoU know, I was a bad
2 little girl and I totally changed. My whole life
Page 41
HOUSE OVERSIGHT 012322
2007-04-25 -IXT
3 changed. A couple times after I had the baby, I brought
4 a couple girls there. It was like two times. And then
5 me and Jeffrey really stopped talking. we just stopped
6 talking. I had my own life and he had his, so I don't
7 know.
8 BY AGENT RICHARDS:
9 Q. Did he ever make any arrangements knowing that
10 you wanted to be a model or were modeling? He has a lot
11 of connections with photographers and stuff. I mean, did
12 he ever set up any photo shoots or anything like that?
13 A. No. No, because he asked me if I would like to
14 go to pursue what I wanted to do, but like I said, for
15 the second time --
16 Q. I mean in town here, not to travel to
17 for a shoot or anything?
18 A.
19
20 BY MS. BILAFONIA:
21 Q. Did you ever get money from Jeffrey when you
22 didn't either give a massage or bring a girl over?
23 A. Yes.
24 Q. Okay. When did that happen?
25 A. I had to pay rent and I was late on my rent.
N;
,etause
that because nt
VW:A.4W like stooc
Page 42
:now that
New York
ac
41
HOUSE OVERSIGHT 012323
1
2
3
4
Q.
6 A.
7
8
9
10
11
12
13
14
15
16
17
18
19
20 he gave you?
21
22
23 to choose one, so I chose one.
24
25 anything like that?
2007-04-25 M.TXT
This was before the baby. And i asked him -- I asked him
for like 300. 00v000#0t
$500. I don't --
tell you how I got it.
Q.
A.
anything) I thin
couldn't
R4:100t.:MW
Was he there when you went to get the money?
NO.
Do you know was he in town or did you call him?
don't even -
'-remeM,
remem e
the house
us
Q. Was that the only time that he gave you money
that wasn't connected either to a massage or to bringing
a girl?
A. He bought gifts for the baby shower. I can't
remember now. Not off the top of my head, no. I never
asked him for anything because I just felt -- I'm not
like that, you know. I'm not a user and I'm not -- I
don't like that. I've never asked him for money, so --
Q. What about presents, either birthday presents?
You mentioned gifts for the baby. Any other gifts that
A. Yeah, he gave me a -- he had went to Brazil and
he came back with a whole bunch of bikinis and he told me
Q. Any other gifts, Christmastime or birthdays or
Page 43
HOUSE OVERSIGHT 012324
/
! 2007-04-25 TxT
42
1 A. No.
2 Q. Did he give any of your friends that you
3 brought gifts?
4 A. Yeah, the girl who died, He gave her
5 a bathing suit, too, from Brazil.
6 Q. We have some telephone numbers that we wanted
7 to ask you about.
8 BY AGENT RICHARDS:
9 Q. Just to see if you recognize these or if you
10 ever used any of these numbers that might have been old
11 telephone numbers for you at some point. I don't know
12 how many cell phones you may have had through the years.
13 See if you recognize any of those.
14 A. was my number.
15 BY MS. BILAFONIA:
16 Q. what was 's number?
17 A. 's?
18 Q. Yeah.
19 A. What, my baby's father?
20 Q. Yeah.
21 A. oh, I never knew his. Always I just, you know,
22 called him and I never knew his number.
23 BY AGENT RICHARDS:
24 Q. It was programmed in your phone?
25 A. Yeah. So I don't know. 1 just know
Page 44
HOUSE OVERSIGHT 012325
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2007 -04 -25MXT
43
1 because that was my old number like a long time ago.
2 BY MS. BILAFONIA:
3 Q. At the time that you were bringing girls over
4 to the house, were you also working a regular job?
5 A. I worked at City Pizza for a little while, but
6 no, kind of retired and splurged. I didn't have any
7 bills to pay. I saved. I put money in the bank, so
Q. we had talked about _________________before. DO
you know someone named
A.
Q. And who is that?
A. i brought her a couple times. who is that?
Q. I mean, did you go to school with her or how
did you know her?
A. oh, i had asked one of my friends. I said do
you have any -- It was a guy friend. I said do you have
any girls that are willing to give massages and I met up
with her. I called her. I talked to her on the phone.
met up with her and she said yeah, cool.
Q- 4h4g460440igto01040104001t
Iittifit#0
A •yeah, she wetit over there more She went over
there an a coup
U broug
Page 45
HOUSE OVERSIGHT 012326
2007-04-25 TxT
44
1
2 Q.
3
4
5
6
7
8
9
10
11
12
13
14
15 A NO-
16 Q No, one
17 A. No, no, 0
18 frorg
19
20
21
22
23
24
25
A. That I know of. That I know of, yeah.
Okay. Did you ever tell any of the girls that
they would be goingNigiii610CIA6.4
A. $6 I told them we were going to go Jeffrey's
house and it's going to be a topless massage pretty much.
Anything you don't want to do, you don't have to do and
it's $200, badda-bing, badda-boom. You make $200 in 30
minutes.
Q.
e girls complain -4046
4.0000iCatWOO_ left 000:
W Yu asked me that questio No 006hOW
loved Z:;
Q. No one called you and said, I think that you
should call -- I think that we WOO OW00001t0$6
COO4t
God. And who is that comiri
Q. We just have phone calls that seem to
contradict what you're telling us?
A. oh, so you think that people came to me and
said that I'm to call the police on Jeffrey?
BY AGENT RICHARDS:
Q. Was there anyone that thought that what Mr.
Epstein was doing was inappropriate and was concerned
Page 46
HOUSE OVERSIGHT 012327
2007-04-25 TXT
45
1
2
3
4
6
7 food.
8
9 Q.
10
11
12
13 A
14 linderag
15 hopefully
16 does
about that?
A. Every girl ...a lii,;14,iiii •::,
.ffrev, the:saidt
161 iiiiiilliiiiilli it. Arid
...................................... 'Wil!:......:'nr ni girkL.,60090gOillit40#1fh#C
comeback for the money. And as
far as I know, we all had fun there.
..0
Lye us free
400445413Rt40;
mean, was there anyone that thought what he
was doing may have been a little bit wrong? Not wanting
to report to the police, but just saying, you know,
that's kind of weird?
17 calling the cops.
18 BY MS. BILAFONIA:
19
20
21
22 was somebody shocked --
23
24
25
because.: were
But other than that, not
Q. Was anybody upset that he was masturbating?
know that you said you told them that they would possibly
do the massage topless. They might have expected that.
A. Yeah, of course. I mean, he always told them,
okay, and i told them, too. r1..sai1d
going to qo
anythini
at
Page 47
HOUSE OVERSIGHT 012328
2007-04-25 TXT
46
1 cOm ortable
2
3
4
5
6
7
8
9
10 BY AGENT RICHARDS:
11
12
13
14
15
16
17
18
19
20
21
22
23
24
A couple girls when they did come out
of there, they're like oh, my God, I wasn't expecting all
of that, but he always asked them and I asked them.
They A say that you know he asked me are you
OfiifiiftV e with this and thy1d say.yg.'§ Maybe they
were scared, who knows. But yeah, they came out of there
like oh, my God, that was kind of weird, you know, yeah.
Q. Were any of them upset about it?
A. Do they like regret it or something?
Q. Just shaken up, you know, just kind of shocked?
A. A couple of girls -- well, see, we were so
young and Jeffrey didn't know that. Like the whole thing
was shooken up when I brought them there.
And see,
uple times that I had
whatever, if they were like shooken up, I'm like it's
okay, you know. And they were like oh, I wasn't
eY were li
ONCW'
ook up about
But and afterwards like if he climaxed or
Page 48
HOUSE OVERSIGHT 012329
2007-04-25 .TXT
25 expecting that, but they told Jeffrey that, you know,
47
1 they were comfortable with it. If anything, you know,
2 maybe they were scared and they felt like obligated, like
3 they didn't want to say. I was thinking that they didn't
4 want to say like no, you know, I don't want to do that,
5 so who knows. I wasn't up there with them, so I couldn't
6 tell you.
7 BY AGENT RICHARDS:
8 Q. Who were the ladies who mentioned that to you
9 who were kind of shocked?
10 A. usually, the girls that I would bring like one
11 time and I wouldn't even see them again.
12 Q. Can you help me out with some names, though?
13 A. Huh-uh, no. I can't remember her name. She's
14 on the top of my -- oh, my God, I don't remember.
15 can't remember.
16 BY MS. BILAFONIA:
17 Q.
18 authorities? Nobody was that upset that called you or
19 spoke to you that was upset with what had happened to the
20 point that they wanted to report it?
21 A. W no if anything,thank
None of girls wantec
22 because
23 BY AGENT RICHARDS:
Page 49
_Pgm
.0 the
HOUSE OVERSIGHT 012330
2007-04-25 TXT
24 Q. Do you know the names of some of the girls that
25 you brought?
48
1 A. Huh?
2 Q. Do you know the name of some of the girls you
3 brought other than the ones that we've talked about right
4 now?
5 •A. Like I said, I can't remember because usually
6 there --
7 Q. There's about 30 of them, so you've got to
8 know --
9 A. No, I don't know because there were girls that
10 I didn't even know so, you know, I just asked them.
11 said, Hey, would you like to make some money? Here's my
12 number. Do you want to make money? Here's my number,
13 you know, and that's how it went. So I don't remember
14 the names and I really didn't care to know their names,
15 anyway.
16 Q. Do you know their phone numbers?
17 A. Now?
18 Q. Yeah.
19 A. No.
20 Q. Do you know any of their phone numbers?
21 A. No, no, no. That was years ago.
Page 50
HOUSE OVERSIGHT 012331
2007-04-25 .TXT
22 Q. We're just trying to find any other ladies out
23 there that we haven't already seen and you brought 30 of
24 them and we're just trying to --
25 A. I don't know if I brought 30 of them.
49
1 Q. Approximate?
2 A. Yeah. No, I have no clue, no idea.
3 BY MS. BILAFONIA:
4 Q. Did you stay in touch with any of the girls
5 that you brought?
6 A. Huh-uh.
7 Q.
8 talked about? DI,
9
10
11
12
13
14
15
16
17
18
19
20
any of the girls that we've
you ever when yi were eithe
iris or when you were givin
WAORION*1001W
Pges,07-kPtIm4rP8%4?
A.
Q.
9VA
10W400iiilbi6
massages, di
rugs, whether
Page 51
V4001i5.4
iculaUs
AoW#ONO0E0(14
*64*.gi00$0,064:.&ë usinq.
HOUSE OVERSIGHT 012332
2007-04-21111111ITxT
21 Q. And just so you know, =, we're not talking
22 about necessarily crack cocaine. We're wondering if
23 anybody was taking any prescription medication?
24 A. I don't know if they were taking prescription
25 medication. That's their problem. I don't know.
50
1 Q. And you didn't give anybody else any
2 prescription drugs?
3 A. No, no. when I was 16, I smoked pot, but no.
4 (start of Tape 2.)
5 MR. EISENBERG: Okay, gang, back on the record.
6 And I assume you mean prescription medication not
7 for prescription purposes?
8 THE WITNESS: I thought you meant like for
9 prescription, prescribed. No, I don't know.
10 AGENT RICHARDS: okay.
11 BY MS. BILAFONIA:
12 Q. But you weren't taking any anti-depressants or
13 pills or anything?
14 A. No, no, I just smoked pot. But I mostly went
15 there sober. I was comfortable with Jeffrey. Jeffrey
16 always made me feel so comfortable. I thought I was a
17 big girl. I was 18.
18 Q. You said that you stopped. why did you stop
Page 52
HOUSE OVERSIGHT 012333
2007-04-25 XT
19 going over there? You said you had a baby and you
20 changed?
21 A. Yeah.
22 Q. what happened?
23 A. Everything changed in my life, everything. I
24 ended up getting a job and I just stopped. I just
25 stopped. I don't know.
51
Q.
'f0J&;,.so: WM OtAt.01
over th
ere?
3 A. I just stopped because I have a son now and
4 didn't feel like it was right. First off, I was a
5 stay-at-home mommy, okay. And what am I going to do,
6 bring my son over there to Jeffrey's, no, you know. So I
7 focused on my son. I had a beautiful baby boy that was
8 my pride and joy. I didn't care for anything else.
9 didn't care to tell friends. I dropped all my friends.
10 Like he asked me do I have any numbers, no, you know. If
11 anybody does call me, that's my mother. Like it was just
12 me and my baby boy and it's been like that ever since.
13 BY AGENT RICHARDS:
14 Q. Having a baby is a life-changing experience,
15 isn't it?
16 A. Having a baby?
17 Q. Yes, it's full-time.
Page 53
HOUSE OVERSIGHT 012334
2007-04-2511111111TxT
18 A. Awesome, I love it. I love it.
19 Q. Yeah, he'll be two in August.
20 A. Mine will be two in June.
21 BY MS. BILAFONIA:
22 Q. Is that when you started working with the
23 company you're working for now?
24 A. well, I was -- the whole time I was pregnant,
25 was taken care of by my baby's father. Then I was a
52
1 stay-at-home mommy for eight months. After that, I
2 worked at LA fitness, Romeo Pizza. it's,been a year now.
3 And what do you mean, is that why I'm working?
4 Q. No, I just didn't know where you were working.
5 I thought you said you had gotten a job afterwards, after
6 the baby was born?
7 A. Yeah, I worked at the laundromat for a couple
8 of days. I just like to -- I wanted to soak in my son.
9 That's all I did and I was like a hermit crab in the
10 house, you know. And if anybody -- I told -- I told
11 I said, you know, I have a baby now and you know,
12 I'd rather stay at home with my baby. My old man was
13 taking care of me. i didn't care about money.
14 Everything was good, so a new life.
15 BY AGENT RICHARDS:
Page 54
HOUSE OVERSIGHT 012335
16
17
18
19
20
21
22
23
24
25
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Q. Slaaa
• 2007-04-25 TXT
qng-of-wor ,.....1dienyotvsetuva
XIIMMents:
with
refer t.
e  girls were doing as
work,. 1i
massage
A. NO.
Q.
go over
jefti4i for
-- how did she -- were any terms used or just
in general? Did she ask you if you had any girls that
can work or did you have any girls that can come over?
Do you have any girls that can give a Jeffrey a massage?
How did she ask for these appointments?
A.
would like to come ov
*MA like to WOORZ.i
mean, me and were—
53
assa
wa
Q. okay.
BY MS. BILAFONIA:
Q. You said that you and had developed a
friendly relationship. Did ever tell you what types
of girls Jeffrey wanted or I think you said that
sometimes she would say he likes this girl or I'm sorry,
he likes this girl?
Page 55
HOUSE OVERSIGHT 012336
2007-04-25 TXT
15 A. Yeah.
16 Q. what exactly -- what guidance did she give you
17 about recruiting the girls?
18 A. she didn't give me guidance. Jeffrey from the
19 get-go, I really like women like you. so when I would go
20 searching to make money or whatever or my girlfriends,
21 know what an attractive person looks like and I would --
22 I would bring them, you know. I didn't bring any
23 overweight people. I just knew what Jeffrey liked, you
24 know.
25 Q. Did you ever talk to massages when you
54
1   gave them, what you did, what you would do?
2   A.   Huh-uh. TA
3   Q.   I have a picture of someone and I'm just
4   wondering if you recognize this person?
5   A.   No. was she a girl that was over there?
6   Q.   Just a face that we wanted to
7   A.   okay. No, I don't know.
8   BY AGENT RICHARDS:
9   Q.   When you would ask the ladies if they'd like to
10 go over to see Jeffrey, what was the percentage? How
11 many people would say sure, that sounds good. Let's go
12 do it. And how many would just say, no, I'm not
Page 56
HOUSE OVERSIGHT 012337
13 2007-04-25 .TXT
interested. mean, do you have -- how often when you
14 would ask the girls --
15 A. It was usually girls that I brought, the girls
16 that I had brought 141Wfit4g090AIM say, I would
17 say, Listen, girlfried.s and it
18 MAAt.t'40;Udown thetikt Recruit your girlfriends and x
19 will pay you guys. So if I was off the wall, say I was,
20 you know, at a club or something and I was like hey,
21 girl, do you want to -- they'd be like you're crazy, you
22 know.
23 Q. That's what I wondered, when you approached
24 them what was the reaction?
25 A. But when I talked to them over the phone, if it
55
1 was one of my girlfriends' friends or one of their
4
rn:. exactly an they'd be like
wmikp: '
Wou know, how your morals are or whatever, if you're
5 comfortable with your body, if you're comfortable with
6 giving an old man a massage for $200.
7 Q. For 30 minutes.
8 A. You know, everybody is a different person.
9 Q. Sure.
10 A. But most of the girls were -- they were like
11 yeah, sure, yeah.
Page 57
HOUSE OVERSIGHT 012338
n't t
2007-04-25=.TXT
12 BY MS. BILAFONIA:
13 Q. Did you ever say anything about, you know, be
14 careful who you talk to about this or I guess I'm
15 wondering why, you know, were rumors going around at
16 school or how did everything keep under wraps?
17 A. Everybody knew. I don't know. Everybody made
18 jokes about it. Like it was not in school. It was more
19 like in my neighborhood. They would call me Heidi Pleish
20 and everybody just made jokes about it. I don't know.
21 It wasn't -- but I didn't care.
22 Q. Right.
23 A. You know, it wasn't if you didn't get out -- it
24 wasn't really a big thing to me at all.
25 Q. I guess I'm just wondering, you know, kind of
56
1 the way that this all came out was finally a parent found
2 out about it --
3 A. Yeah, I heard.
4 Q. -- and went ballistic. How did you keep these
5 girls' parents from finding out?
6 A I don't know, probably embarrassing. They
7 cbviously liked efirey that nnkh that.thg.
8 anyone.
9 Q. Did anybody hassle you at school? Did anybody
Page 58
HOUSE OVERSIGHT 012339
2007-04-25 .TXT
10 call you Heidi Fleish at school?
11 A. NO, no, no, I was out of school by then, No.
12 Q. why did you drop out of school?
13 A. Well, actually, -- Why?
14 Q. I'M sorry. I interrupted you.
15 A. Because -- no, you didn't, well, my mother had
16 took me me out of school to home-school me. And then I
17 had went back to a school because i was really behind
18 because she didn't home-school me and I had got pregnant,
19 that's why. And that's in the eleventh grade, that's
20 when I got out because I was pregnant. And I decided
21 that I was -- I mean, I didn't know what I was doing. I
22 wanted to have a house. I said I'm going to have this
23 baby. i need to have a house, a car, and I set out all
24 my goals and that's what happened. But then I ended up
25 getting my GED and I have a life.
57
1
2
.4
6
7
8
BY AGENT RICHARDS:
Wzre them
wanting work over.
work over there and make.S ck
that?
A.
Q.
Do you remember any of their names or were they
classmates or --
Page 59
HOUSE OVERSIGHT 012340
2007-04-25M. TXT
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 any of us, for me or --
25
1
:4:
5
6
A. to but hope
A. It wasn't --It wasn't involved in the school so
much. It was just that girl in the school.
Q. okay. so she was really the only like
school-related --
A. Like person from school, yeah.
Q. okay.
A. BUt it was mostly out of school. So I wasn't
really hanging out with the best crowd. And all the
people that I did hang out with, they were dropouts. So
it wasn't anything in school. It was mostly like the
neighborhood people or my friend, one of my guy friends'
girlfriend or whatever, you know. We were all young and
stupid, but --
BY MS. BILAFONIA:
Q. Anything else? Do you have any questions for
- h
0 e Jeffrey, nothing
tobilowt_
ecam
awesome man arid
.11:0X11.10gAWFPF!
Q.
46:A.
58
awesome
Are you in love with him at all?
A. My God, no. I love him as a friend.
Page 60
I love
HOUSE OVERSIGHT 012341
2007-04-25 TXT
7 him as a friend. He has done so much for me. No, I'm
8 not in love with him. I tell Jeffrey, do you want to
9 marry me with all of the money that you have.
10 AGENT RICHARDS: All right. At this time,
11 we're going to conclude the interview. It is 5:34
12 by my watch.
13 MR. EISENBERG: The only thing we'll correct is
14 that there might have been a reference to an old guy
15 at 50 and we'll just say a more mature individual
16 who may be in his 50s. Thank you.
17 (End of the tape.)
18
19
20
21
22
23
24
25
59
1 CERTIFICATE
2
3
4 The State of Florida, )
5
Page 61
HOUSE OVERSIGHT 012342
2007-04-25 TXT
6 County of Palm Beach. )
7
8
9
10 I, Vicki S. Woodham, Notary Public, do hereby
11 certify that I was authorized to and did listen to and
12 stenographically transcribe the foregoing tape-recorded
13 proceedings and that the transcript is a true record to
14 the best of my ability.
15
16 Dated this 26th day of April, 2007.
17
18
19
20
21
22 Vicki S. Woodham
23 my Commission Expires:
24 December 08, 2010
25 Commission No.: DD617559
60
Page 62
HOUSE OVERSIGHT 012343
2007-04-25 _TXT
Page 63
HOUSE OVERSIGHT 012344
TAB 7
HOUSE OVERSIGHT 012345
Page 1
IN RE: OFFYREY EFS=IN
TTIPEF, TN7ERVTF
!s7otzl-y
find
Phort -
Op.
•
J. Consor & Associates Reporting & Transcription
561.682.0905
98ae64ed-fabf-461a-b5d2-be85289cc516a
01910
HOUSE OVERSIGHT 012346
Page 'I
(fhereupon, the following interview was had])
DETECTIVE RECAREY: -- December 13th, 2005.
This is ID number -- Detective Joe Recarey with
the town of Palm Beach Police Department. Present
is Detective Dawson with the Palm Beach Police
Department.
BY DEFECTIVE RE CAREY:
A
0
A
A
Can you state your name for the record, please.
S:lel] it lease
Your date of birth?
ow old are you'?
A Seventeen.
Q Okay. Vol] saw I just spoke to your mom and she
has given me anthorr,zation ro speak to you. I am
investigating a case involving a gentleman by the name of
Jeffrey. You may know him as Jeff or Jeffrey lives in the
Town of Palm Beach. We believe that you may have some
information pertaining to his residence ancPor a visit at
his house. I'm going to ask you in your own words tell me
exactly what happened fr.im the beginning. I may interrupt
you to ask you some more questions 'out before we begin. can
lapse your Oulu hand for ine. Do yt,11 solemnly swear tO tell
the truth, the is truth and nothing but the multi so help
you God.'
A I do.
Q Okay. 1-,otiii!AO.vdtkinit,..:i.O]vhci*..ydti4iIU
A (Inaudible) not really friends. 111111160:m.g
:v-ANN thin she found a as of Making mcney.'mu can pet
money. And then she said that ift ever told anybody she'd
beat my ass and so 1 didn't even know what she was talking
-- okay.
Right
bellse we got m there she's like oh, he might ask you to
like take off your shirt or something. Hut I didn't -- it
didn't matter Si' I said okay. And I went in his house. A
Lady escorted me up to his room. Had a bed on it.
Q Okay_ I.e.! n hack ui up for a second
A MI huh.
Q You said this was right before Christmas.
Christmas of last yea' in the yea! beliiie?
A Last Year
Q Last year.
A Oh-hoh.
Q So tins is December of 200.1, righil
;
4
.t
A Oh-huh.
Q Okay. How old were you then?
A I think 16.
Q Okay.
A And then I went up there. He was on the phone and
6 he just told me to massage his feet so I went over there and
7 did it. (Inaudible) and everything and then
Q 1 told on for a second. Hold on. Take me from when
9 you got to the house in Palm Beach. First of all, do you
7. remember the name of the street'?
A You said it before but I just can't remember.
Q Okay. Do you remember any specifics of the house?
A I know where it is if I were tc: go back. I could
find it.
Q Okay.
.; A It was at the end on the left side.
Q The end on the left side? Okay. Do you remember
the color of the house?
A Oh. It was too long ago.
Q Okay. I know it's been some time and we did speak
. once before
A lib-hub.
1 7
1
L
0
A
All right. So you were walking in with
Uh-huh.
Q Okay. Take me from clo you go in the front door?
. :
Do von go through the garage?
A No. You 2.0 to the sick gate. You have to knock
on the back door kind of.
Q Lilt-huh.
A And a lady will ask you like what's your name and
why you're there.
Q Okay. What's the lady's nante? Do you know?
A No. I think she was the maid because she was like
InkIng. up towels aid she was bringing Mem upstairs
Q Do you krow -- can you describe her to me?
A She might be a Spanish lady. I can't remember so
0 Okay.
And when you walked in, there was food on the
Inhale. I bey offered you (laid. And I waited a couple of
minutes. I guess he was in another session_ I don't know.
Because like a girl walked out before I walked in and this
really pretty lady. he walked in with two ladies and they
were like_ they looked like models or something and one had
blond long hair and one of Mein came down and told me I
could go upstairs. .fhat's probably her. And as we were
walking up the stairs she told ine what was going to happen
like well, he's going. to have some lotions there and he'll
probably be on the phone for a little while.
Q Okay. Did the blond lady with the longhair take
J_
2 L.' ages
Consor & Associates Reporting & Transcription
561.682.0905
98ae64ed-fabf-4618-b5d2-be135289cc56a
01911
HOUSE OVERSIGHT 012347
Pricie A
9
1.1
12
13
1 4
e
16
YOU upstairs?
A Yeah.
Q Okay. How does she take you upstairs? How did
VDU --
A She just said follow me.
Q Did she -- did you go up a big staircase? Little
staircase?
A It was like a living room. It was the kitchen and
than a living room and you turned right and then it was like
a staircase that would hke I :,.ness it's kind of-- like
spirals.
Q Okay. Did she take you to where?
A It kind of looked like a bathroom hut there was no
toilets. It was a cold room and it had like a sauna in
there.
Q Okay. It
A A big sauna. Just table where he was going to
lay on. A place where you could wash your hands and it just
kind of looked like it was a room for that.
Q Okay. Okay. So take me from there.
A He turned the lights down some and he was on the
phone. lies like oh. just (inaudible) lotions are here and
you can start by rubbing 111V feet. So I put some lotion,
rubbed his feet. and then he told me to rub his calves. his
legs or whatever. And then Lin trying to remember. And
1 Ycult. arid then he wanted me to rub his back. I started up
2 top and then lie kept asking me to no tower and lower and he
3 still had the towel on at tins point and then when I got
1 right to where his -- right above his like butt like kind of
right above here --
Q Oh-huh.
7 A -- he like flipped over and he just told me to
A like man rubbing like his stomach and stuff like that and
his chest and then he told me, he's like why don't you just
take off your shirt and pants. I was like (inaudible). so I
11 did that and then --
12 Q You had your shirt and pants on when you were
nibbing his feet and calves?
4 A Uh-huh.
15 Q Okay. You took off your pants and shirt.
16 A Uh-huli.
Q Okay.
_ to
1
A And then like he got more (inaudible) and he took
off his towel.
Q Okay.
A I don't really like know why he was doing that but
and then lie he was kind of like talking to me like trying
to get to know me about my sex. life He's like oh. you're
such a beautiful girl. He's like well what are you like
when you have sex. I didn't really answer him. I was like.
2
3
6
1
4
2
21
well. I don't really like to do anything. (Inaudible) a
massage. 'that's it. And he's like nh but you're so
beautiful. And he kept saying that for some reason.
0 All right. Let me stop you for a second. When he
took off his towel. was he completely naked'?
A lih-huh. Yes.
Q Okay. And you were in bra and panties'?
A Oh huh.
Q Okay. Okay. 'Fake me from there. So he took off
his towel_ he's telling, you how beautiful you are.
A And lie told me. he told me to nib his nipples like
he's like oh. just pinch them or something_ And I was like
all rirlit. And then he had one hand on his P.
Q Okay
A And then he like tried ribbing on my priyes
(phonetic) and he had like the middle of my bra was the snap
off part and he like snapped it off and he \NTS trying to
led l my boobs and then he just grabbed my thighs and he was
jacking hunsell oil at the same time and then he went down
to -- should I say Mat?
O Say it.
A Nly vagina.
By DITA Ec•rivE DAwsom
Q We've heard it all
A Yeah. And he like didn't take otTmv panties but
he like pushed them to the side and he's like feeling down
there and he's like don't won-y. don't worry. I'm not going
to go in, da do do. It's so we i rd I'm like anyway. And
then he stared rubbing down there and then he started
talking dirty. He's like au, your c lit feels so hard and
stuff And l like backed away. I was like (inaudible).
O Okay. At any time did you tell hint no? Did you
tell hint you're not comfortable with this?
A I hacked away and I said I otis like well. I don't
know if I shouki do tilat and I was like very hesitant and so
seared that I didn't know what to do. Kind of like you just
want to ret ii over with to get it over with. And then --
and I 'was feeling so ieitsc.: guess that's why he was
saying it. And then he actually stuck his fingers in there
end I hacked away again. He goes oh, don't won-y, don't
worry And he's like okay. fin sorry. Then he went back to
the outside and he was still jerking hinisel ruff mid then
finally he finished himself. wrapped up his towel and said
there was S200 on the counter and then there's an extra
hunched for iike oh. I'd like to see you
again. I was like yeah, I don't knov.'.
Q Okay. Let nie bring you back to when he snapped
oil your bra.
A I ih-huh.
When he snapped it off. did you take it off or did
J.
(Pacies 6 7.0 9)
Consor & Associates Reporting & Transcription
561.682.0905
98ae64ed-fabf-461a-b5d2-b€035.289cc56a
01912
HOUSE OVERSIGHT 012348
Page I LiI
he slip it off of you or did you just have it on and it was
2 just hanging?
A Yeah, it was just hanging. He had snapped it off
4 and it was just right here.
Q Okay. At any time did he touch your breasts?
A Yeah.
Q When -- okay. So you're standing there, your bra
8 has been unsnapped. What kind of panties did you have on?
Do you remember?
A Athmg.
Q Affione
A Uh-huh.
Q He started touching you on the outside of your
panties or did he 1110%.12 your panties to one side?
A On the outside first and then he moved, he moved
them over.
Q Okay. And then he started touching you on the
outside of your vagina?
1 9 A Uh-huh.
2 n Q And he told you he was not going to go inside.
21 A Yeah.
Q At what point did that change'?
A When he started feeling down there and then
21 when -- pretty soon.
25 Q When you say Fltgers, did be use more than one
.. ......... .
3
34
37
finger?
A I think he used two but I don't know,
Q Okay.
A And [lieu after Judd him, I backed away and I was
5 kind of like shaking my head no, he's like okay, I'm sorry.
O And then he kind of still put his fingers down there. He
was just like pushing really hard on me like, f don't kuow,
• he just, it just fed like Ins lingers weren't in me but it
• was ciose enough to where it still felt weird.
1 S Q How did you __ how. did -- when he had his lingers
ii inside you, on backed up to eel them out or --
I. 2 A Yeah. And to let hirn know that I don't want to do
-3 that.
Q Okay. And none of this was told to you by
that this would happen?
A No.
Q Okay.
A That's why when I got out I was freaking out but 1
didn't even say anything to her and then she asked me what
happened and I told her what happened and she said oh. it's
okay. He did that to one of my other friends 1 brottaht
2 here. And I was like and you let him do that and still got
7 MC in there? And she's like oh, ifs okay. You got 2.00.
Does it matter? I said did you have to do that? She said
no. 1 was like all right, then you don't know how it feels.
Pa 12
She's like let's just go shopping and stuff and I was like
no.
;I Q Okay. During this time that this was occurring,
; 4 he was jerking off you said'?
A Uh-huh.
Q Okay. What does that mean to you'? I mean like is
▪ it something that -- do you know v.-hat masturbation is?
8
3
-2
23
9
I Lt
A
A
Yeah.
Is that what you consider
Okay. Did you -- sorry.
A That's Okay.
Q Do you know \vital a circumcised and uncirouncised
penis is?
A Umm, then (inaudible.) No. I krow what it is.
Q Okay. Did you visually sec his penis'?
A Uh-huh_ Yeah.
Q Would you say it was circumcised or uncircumcised?
A I would think it would be circumcised but I tried
not to look.
Q Okay.
A I was kind of just like looking ali.ay because I
didn't want to see what was actually happening.
Q Okay, You said that he had finished.
A Ile came.
Q Okay.
A Because he was like a big sigh of relief like he
had been done and he just got right hack up and --
Q Do you know where he came an'? Was it on the
towel? Was it on himself? On the bed or --
A 1 think it was on the towel like right between Ins
:eg,s probably.
Q Okay. As 1 told you before. and I explained to
your mom, what he did was wrong, o'say?
A 1.311-hui.
Q l want to reassure you on that. Okay'?
At any point did be ever ask you to leave your
phone number or --
A No He didn't ask nte for anything. like I think
he asked me my name in the begualir.14.
I'Ytd tie kno'1viai at,
A Ftlo&t'igiAc
P4,!0.04.0
: 9
old 'is'e+,oi1Just,ay.ye
0].4!]efAip.
,
23
.................
dd
....................................................................
Q Do you have any formal massage training?
A No. That's why I thought (inaudible).
Q Okay. How long would you say this session lasted?
J. Consor & Associates Repo=ing & Transcription
561.682.0905
983e64ed-fabi-461a-b5d2-be85289cc563
01913
HOUSE OVERSIGHT 012349
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A Probably like around 45 minutes.
Q Forty-five minute.s? Okay.
You said he wonted to see you again. Did the
blond hair lady try to take your information or --
A lie said oh, well; I think gave my
secretary your name and number and sruff and I'd like to see
you again and --
Q Did anybody from the house ever call you again?
A Ilub-huh.
Q Nobody ever called you?
A No.
A
A
Okay. So you only went there that one time
Yeah.
Okay. Is there anything else you'd like to add?
Yes. There was another girl that like
Pacfe 16
DETECTIVE KE.CAREY: Okay. Can you think of
anything else?
3 BY DETECTIVE DAWSON:
4 Q Was he in good shape? Was he a blob'?
• 5 A He was old but he wasn't as muscular or anything
• 6 like that. He was like a regular old guy.
BY DETECTIVE RECAREY:
. 8 Q Did he have any accents or anything or
A Huh-huh. No.
' ' Q Did he ever introduce himself to yon2
A No. That's why I don't know who you're talking
about. I guess I heard that name in front of
(Inaudible) took notes on his name or anything.
Q I know this is difficult for you and I know it was
difficult from talking to you the other day and it's
difficult talking to you now.
A Uh-huh.
Q But I've talked to a lot of people and I really
appreciate you talking to me about this.
A Oh-huh.
Q Is there anything else you'd like to add to this
statement?
A No.
DETECTIVE RECAREY: No? I'm going to go
ahead and conclude this statement. The time by my
1 ,
there were other rumors like they were partners in doing
that.
Q Who was that? 7, 8
A This girl I'm not. I'm not quite sure_
My brother would probably know because she's older than us t
because she met her at Publix afterwards and went 2_
and gave her some money. I think they had to share the $100 2
that they did. (Inaudible) a hundred bucks. And (hen 1
heard another thing at my school that there was like a rumor ' 21
about this other girl it happened to. I just didn't say 25
1 anything because I didn't ‘‘ant anyone to know about me.
2 Q Do you know who the other girl was?
'r< A I could ask.
Q No. Don't worry about it.
5 A Okay.
6 Q Did he know you went to
A I don't think he knew anything about me.
9 Q Like the quest:ons that he asked you in trying to
• get to know you, what kind of question I neon other than the
11 sexual questions'?
2 A He didn't really ask me -- oh, wait, he asked ate
.1 3 what school I went to. lie was just asking inc like how I
1 4 felt because you're pod at massaging, (inaudible) how I got
13 n the business. I thought yeah. 'hard be cool. And he
I 6 tried to ask me so do you have a boyfriend, what do you do
7 liar fun. Pretty much like it was kind of weird how often
I 8 (inaudible). Now do you like to have sex. Oh. do you like
I 9 it when people like touch your [wall's. I said no. I don't
ieally like when pro* touch illy body because I'm shy owl
(inaudible) don't let im.yvne touch my boobs anyway. He did
it.
Q Okay.
2 4 A 130 he kept asking roe like about his nipples
25 Ile's like oh, that feels so good like --
4
1.3
7
23
2 4
2 E.
watch is 5:25 p.m.
(Thereupon, the interview ended.)
- - -
7
(FaLjes 14 to 17)
J. Consor & Associates Reporting & Transcription
561.682.0905
98ae64ed-fab f-461 a- b5 d2-13e 85289cc5 6a
01914
HOUSE OVERSIGHT 012350
Pacji.: 18
CERTIFICATE
3 STATE OF FLORIDA )
COUNTY OF PALM BEACH )
Sandra Rossi. Court Reporter. State of
Florida at Large. certify that was authorized to
and did stenographically report the fargointz
proceedings, and that the transcript is a true and
complete record of the tapc as !isteneci to by me_
Dated this 30th day of January. 2007.
n
1 a
Sandra Rossi. Court Reporter
6 g
J. Consor & Associates Reporting & franscription
561.682.0905
98ae64ed-fabf-461 a-b5d2-be85289cc56a
01915
HOUSE OVERSIGHT 012351
TAB 8
HOUSE OVERSIGHT 012352
Page 1
IN RE: JEFFREY EPSTEIN
DRAFT
TAPED CAP INTERVIEW OF
02505
HOUSE OVERSIGHT 012353
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MS. ROBSON: -- say anything to you about
4 this (inaudible). right?
5 BY UNIDENTIFIED MALE SPEAKER:
6 Q You know we're not going to argue again. We're
7 not going to keep much from you.
8 A I just don't want to rat anybody out. I'm not an
idiot. Come on. now.
That wasn't more of a ratting out. 11 was more of
a
A Complaint?
Q You got it.
A (Inaudible.)
Q You're a smart girl.
A I'm not an idiot.
Q Yeah. No. you're not an idiot_
A Sof guess karma. you know.
• (Inaudible.) I'm kidding I'm kidding. I don't
even know who he is.
A I don't know. Il's such a big -- there's so many
girls out there that have worked for him it's not even
funny.
Q Really?
A Like 1 said, some bring friends who bring friends
Pd ye 3
1 whit bring friends.
DurcrivE Rl:CAREY: All right. You notified
3 Jimmy?
4 I INTD1NTI Fl NMI .E SPEAKER: I notified Jimmy
5 DETECTIVE RECAREY: Give him a call.
6 (Inaudible) 692 -- our ending mileage was 692323.
7 sorry. 6923. Our beginning mileage to head
8 Sack southwest -- Onauchblek ;Inaudihle) white
9 female (inaudible) same mileage 6923.
What was that?
INIDENTLFIND MALE SPEAKER: Fire truck.
R01350N: so when will I know what's going
:o happen?
BYIINIDENTIFIED 51'1:AKER:
Q Well, here's the thing. What arc you doing
ha-non-ow'? Well, no. nere's our goal. We would like to at
least to talk to -- help ine.
UNI DI:NT 1 F1ED MA 1 .1: SPEAKER 2: We want to try
to interview some of these --
MS. ROBSON: (Inaudible.)
13Y UNIDENTIFIED MAI. SPEAK) iR:
Q Right Tonight.
A Tonight free so --
Q Okay'.
BY DET1:..CTIVE RECAREY:
5
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DI___A
(Thereupon. the following interview was had:) 1
2 2
3 3
4
5
Q Tomorrow yon're working')
A Tomorrow I go to saw' from 12 to 4.
BY 1:N1DENTIFIED MALE SPEAKER.
(,) 11h-huh.
A Wednesday I go to (inaudible).
6 Q Well. tomorrow what are you doing after 4:(k?
7 A Nothing.
8 Q Okay.
BY DFTErrivFIZNCARFY:
(7 1)0 you have to go to work'?
A (Inaudible) Thursday
BY LN1DENTWIED MALE SPEAKER:
Q Okay. We would prefer to do it sooner than later
and our, our request from you at this point as we move along
is really for von to make that phone call and introduce us
and sa,vou know, these are the detectives from the Palm
Beach Police Departmoit. I've told them evelything.
They're on their was to your house. Do you know these
girls' schedules by chance or anything like that'? Do they
still go to high school?
A WelkEstill goes to high school. She's a
senior.
Q Okay. And that's, unit's who we want to speak to
tonight. From what you're telling us. we're confidentM
\rill not be going and talking to Jeffrey. Depending on how
Page 4
Page 5
that goes weinight give you a eali and ask you to make
another phone call for us. II' we could break out the list
3 as we drive. make sure we have a little order of obviously
4 based on what you're saying, should be the last on
our list. We don't know if she's still --
6 OF: FEC•11VE RECAREY: =, she's in Orlando.
7 We can do that one over the phut ie.
8 BY ENIDINTIEIED MALE SPEAKER:
9 Q Now didn't von sav she was back though?
10 A is back. Idon't know it' she has class
11 tomorrow but I don't know if she la already or not.
12 Q What kind of class? Is she in college or
13 something'?
14 A Lollege. Yeah, she's up in Orlando. I don't
1.5 know. She !night have already left. What is today? Monday?
16 Q Yeah
17 A Oh. well she might have ahead',' hell today. She
18 had class today_
19 Q Oh. today. yeah.
20 A Yeah, she does. Very rarely lost to see her
21 parents and stuff Like she lives up in Orlando. She might
22 come back once a month on the weekend to visit her parents.
23 Q Now do you talk oMat all oi not really?
24 A Ihung out with her last night. She came down
25 from college and stuff.
2 ( Pacles 2 Lo 5)
02506
HOUSE OVERSIGHT 012354
Q
A But --
3 Q That Y‘as Sunday night So she ii as around jt is(
4 last night.
5 A She was around last night but. like I said, 1
don't -- she might be still here. she 'night be up in Orlando
7 now.
3 BY DETECTIVE RECAREY:
9 Q Okay What about
10 A Oh. 1 don't like her. I don't like her. What
1. l about her'? She never worked for, she never worked for
12 Jeffrey but she's been to his house before. She knows about
I 3 it. Knows about everything that went on. She was the one
14 that was with (inaudible).
Q Okay. Does know=? Do the!,
16 know each other'?
17 A I don't know.
18 BY UNIDENTIFIED MALE SPEAKER:
19 Q Then phonetic) lives like a couple blocks
20 away from yon. yeah?
21 A Yeah_
22 BY DETECTIVE REC.AREY:
23 Q Okay. lives (inaudible.)
24 A (Inaudible.)
25 Q Okay. Why are you afraid of (inaudible)?
1)____RA
MS RI )13SON: So what ii
2 BY DETFCTI VI'. RI ',CAREY:
Q ( lkoy. Well we'll move on.
4 BY (JN11)1iNFIFIED MALE SPEAKER:
5 Q That's our -- right now we want you to help us
6 with an order of who in your mind (inaudible) you're
7 confident was 16 or maybe 17 when they went there, who
8 probably no longer has any connections with Jeff (inaudible)
9 who at least Maybe a dayirikeep their mouth shut.
10 A Okay. Well with  I don't know how old she
11 is because she lied about her age. She lied to me when I
12 first Mei her When I \V Zel 18 she told me she was IS.
13 (Inaudible.) Well she left her purse at my house and she
11 told inc to make sure that I didn't took in her purse. When
-15 I \Y on through her purse. I found her mote license that said
16 she v‘ its 16. So she lied to inc about her age. I don't care
17 allow ii orkingl'or Jeffrey. but --
18 Q We're looking for girls that went upstairs wall
19 Jeff
20 A Yeah.
21 Q Those three or four gals, whatever you can, you
22 ..now, help us OW with here. that is our goal in the next
23 let's say 24 hours.
24 A Okay .
25 Q Is to reach out to as manv of those gmls and it
a not home?
Page 8
Po ye 7
A Oh, no. Fin not afraid you know what it comes
2 down
to? It Comes down to this. Pin not all aid of any of
3 those girls but when I almost rough cries to
4 EllandMwas brought in to our group which was stupid
5 11 and instead being 'nature about what happened three years
ago. Was like NI going to kick your ass. da da
7 and I was like you know what? You talk a good game. Leave
8 ii te idone pretty much. It got ridiculous so I had to change
9 m number and I saw her at (molkiibIC) one night. She
10 i r1Of [ I behind. I go i.ou didn't sav anything to rile
11 all night and when she jumped me from behind she jumped me
12 so whatever. Owls are stupid.
13 BY L NIDENTIFIED MALE SPEAKER:
14 Q All right. Who else v, as on that list von got
t1H7117'?
I 6 BY DEJE(,TIVE RECAREY:
17 1..) 1)o you know a girl named
18 A
19 (Cellular telephone discussion as followsl
20 DE II:C.11W RECARI-:Y: llelo? Yes. I ley,
21 Dahlia. Okay. Right. Okay. Right, right,
22 right, right, right, right, right. Well, that's
23 the case, that's the situation. Right. ()kay.
24 All right. Right. We're gonna meet with her
25 tonight. (inaudible.) Okay? All right. Bye.
Pdge 9
1 might be as simple as we give you a call on your cell
2 phone --
3 A And you call them.
4 Q And you Nny hey, we need you to call this girl and
5 tell here we arc out front because that's one thing we want
6 to do is figure out where these girls live tonight so that
7 we can remll out to them and say hey= we're out in
front of so and so's house, can you give her a call and let
9 I k h bet' ..nov, there's a couple of detectives outside and no,
10 u mere not kidding. the- realls arc there and heads up. You
I 1 knon iihat I n !Calf'
12 A Yeah.
13 Q what we'd like to -- e've got it hall' hour
14 there if ii e can make some details on that so we're all on
15
the same page. that's what we're ping to do.
16 So how many girls was on the list that ‘,Nc started
17 with?
1 B A You asked me if I knew an
19 Q We don't know -- what we're going to need is the
20 lost names of these girls as well. So if you've got some
21 lost names.
22 A 1 don't know- Imean --
23 Q That's okay Imean -- what about
24 A ? I've heard of a gi:-Inamed but I
25 don't know (inaudible), you know? To my knowledge! don't
3 (Paces 6 to 9)
02507
HOUSE OVERSIGHT 012355
1 know. (Inaudible'?)
2 Q No. (Inaudible'?)
3 BY DETECTIVE RECAR EY:
4 Q No. (Inaudible.)
5 A Inaudible). Not that I know of I know a
6 girl named but I definitely (inaudible) not like
7 that.
8 Q (Inaudible'?)
9 A Don't know. I know (inaudible).
10 BY UNIDENTIFIED MALE SPEAKER:
11 Q Besides Mwho clse ended up upstairs with Jeff?
12 A That's it.
13 Q Okay.
14 A
15
16 A (Inaudible.)
17 Q Okay. Do you know their last names?
18 A s last name l don't know. I don't know
19 s fast name. (phonetic).
20 And I know Ms brother.
21 (inaudible) I think the last name is M. I don't
22 know if (inaudible) or anything because I know like
23 (inaudible). It might be
24 Q (Inaudible?)
25 A Royal Palm (inaudible.)
Page 12
1 Sicilian° should have the hong out
2 Q hang out.
3 A ()Hoe a bit. And von should also (inaudible) and
4 I know the first three digits it's
5 it might b but I haven't talked to her in a Nvhile.
6 Q Sc' il We start withEtolught_ based on what y011
JUSE :Aid 'Mould introduce us to
7 who then
8 could introduce us to --
9 A "l'it .len Reyes.
10 DET1ICTIVE RECARIIY: Okay.
11 hangs Out Ir]th
tionig to talk to Obvtonsk nIt
12 last
13 tV lINIONNTIFIED MAU SPEAKER.
Q Right. We want to iivoid ill all costs.
15 So our qt iC5t 01110yo1.1 IS this group of three
16 girls --
17 A l'hey nit kilow cm:11(ithr:r
18
19
20
21
92
23
24
25
Q They know each other
A They all know ezicli other.
Q
A .hey kno‘‘ They know everybody, its
like a group or people ‘‘110 all know each other.
Q Faith (inaudible)
A The only one they might riot know is
(inaudible) but...
Page 11
Q (Inaudible'?)
2 A (Inaudible.)
3 Q Do you know their phone numbers by chance or do
4 you have them in your phone maybe or --
5 A Let me check. Okay. What's the first girl?
6 Q
7 A I know by heart. It's and
8 it's a
9
A I don't even ha\ e in my phone.
11
12 A I know hers by heart. Area
13 code
14 Q How about
15 A no, I don't know her number at all
I 6 Q (Inaudible.)
17 A I'm pretty sure that's her number
18 because that's the only ones I have.
19
90 A I know her brother's number but
21. don't have her number.
22 Q Is that his cell?
23 A (Inaudible.)
24 Q Okay. (Inaudible.)
25 A Uh-huh. (Inaudible.) will have
Page 13
1 Q All we've got is a group of girls that --
cf .A 'They've all heard of each other (inaudible).
3 Q Now do they all go to school \yid] each other to
4 your knowledge?
5 A Some of them. Not all of them but some of them
6 still go to school together.
7 Q Does she still go to school'?
A She still goes to
9 Q
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A I don't know if' graduated last
Pm not quite sure.
might have graduated last year. (Inaudible.)
Q Okay. So theywouldn't have as much contact as
the other group. (Inaudible) that goes to school.
.A (Inaudible.)
Q My office is warm. The bullpen out there is hike
1‘ arm.
UNIDENTIFIED MALE SPEAKER 2 I love the
cold.
BY UNIDENTIFIED MALE SPEAKER:
Q Yeah. and it's a twenty-year old building so
nothing really circulates as well as it should that old but
(inaudible) in the car_
If there's anybody that we need to (inaudible).
we're not going to talk to.
year or (inaudible).
-1 (Pages 10 to 13)
02508
HOUSE OVERSIGHT 012356
1 HY DKrEC'lIVN Rh:CAREY:
2 Q (Inaudible.)
3 A (Inaudible) call her, open your mouth to any of
4 them. -
5 By DFFECTI 12FCAREY:
6 Q We will absolutely tell them that that they would
7 be obstructing an investigation.
8 A the only one that's going to open her mouth is
9 probably The only one (inaudible) say anything
10 would he M.
11 Q Are these girls, you know, are they embarrassed
12 about what they've done? Would they rather nobody know if
13 it possible or are they out there flaunting it?
14 A They don't care.
15 Q Okay That was my question.
16 A These girls don't care. For the must part they
17 don't care.
18 Q Okay
19 A Otherwise they wouldn't do it.
20 Q I tend to agree hut that doesn't mean you --
21 everybody else (inaudible) get in on the action or
22 (inaudible) in general.
23 A (Inaudible.)
24 Q I hear that Oh, okay. (Inaudible) call
25 dispatch. A couple of females, (inaudible) get some
Page 16
Page 15
1 addresses. After were done with• I thinkMwe were
2 talking about next? (Inaudible.) Oh, okay.
3 A Well. 1 don't know (inaudible) well.
Q We should probably try her since she would be
5 leaving. You want to try --=is ulT to college.
A (Inaudible.)
7 UNIDENTIFIED MALE SPEAKER: (Inaudible)
8 necessary.
9 (Two minutes of inaudible conversation.)
10 (lbereupon, the tape ended.)
11
12
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02509
HOUSE OVERSIGHT 012357
TAB 9
HOUSE OVERSIGHT 012358
Page :1
TN RE: JEFFREY EPSTEIN
DRAFT
TAPED INTERVIEW OF
02420
HOUSE OVERSIGHT 012359
2
1____I
(Thereitpon, the following interview was had:)
3 BY DETECTIVN FCAR
4 Q Today's da:e is October 4th, 2005_ This is ID
5 number 7915 Detective Joe Reearey of the Palm Reach Police
6 Department. Piesent at 1301 (inaudible) Road is Detective
7 Michael Dawson of the Palm Beach Police Department
8 ATOM>) you slate VOIR ii;tnt lilt !he rec.:mil')
9
10
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12
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14
15
16
1.7
18
19
20
21
29
23
24
25
A
A
Q
A
A
A
A
Q Okay. Can you raise your right hand for me? Do
you solemnly swear to tell the truth, the whole truth and
nothing but the truth so help you God?
A Yes.
Q Okay.= if you could tell me from the
beginning how you met Jeffrey 11pstein. I know you have some 2
how do you spell your last name?
Okay. How old are you?
I'm Ii,.
F.ighteen. Okay. You're currently in college?
Yeah.
Okay. What ctillege are you attending?
Okay. And your date of birth is?
Page el
1 there's
more to that. More to the massage. Okay? That's
2 why I didn t want morn to be it) here. And you can talk to me
3
about
anything. Okay? Tikc I said, I've interviewed other
4 people already who have told me what transpired in that
5 room. I know it's going to be difficult for you but...
6 A Well, the first hmel went there I did a massage
7 and he was just asking me a lot of questions. lie seemed
8 like really nice. And then he kept like staring at me and
9 stuff. And then like I did a massage and he just kept
10 looking at me Lind he was like oh, you're being shy and I'm
11 like yealt. NomotOgo•00:(0.0*.0400klogigE-ogt
was Ijkc he's-like
.10.i.;;WW0;141i3Vataikiiit
14 And he was like why are you like being shy and I was like
15 oh,Idon't know. Anti then he would like change the subject
16 and he started talking shout other things. And then hen we
3 7 were done he said that if like I wanted to conic back tind do
18 more then he would like pay inc more and then I would have it
19 talk to Haley and I could come back.
20 Q Okay. What kind °I-questions did he ask you as
21 you were massaging him?
22 A He was asking about -- it was a year ago.: don't
23 remember everything but..
24 Q Right.
5 A He was just asking me it'll-tad tui friends that
4
5
6 A IiiigNifii;i3i6.405,i* fOiie
7 Q Okay. How long ago was that?
8 A It 11:.:: probably about almost a year agi.
9 (,) Okay. Okay..
1.0. A Aiiafia.-;,,,t1-;::Wakihi;iE;aW'Avilgii.gi'ijigij,•4iiii.siive
V.A:t
:105116,ifilidiitk whatever and then after that like he kind
13 of scared me when I went there sol just decided not to go
14 back..
15 Q Okay. The first time you went will you
16 go umstairs with him?
17 A No, I stayed down in the kitchen, (Audio at 2:03)
18 Q Okay. Did tell you that -- what was
19 entailed as to what had to he dime?
20 A Well she said the first lime you go ifs just like
21 a IrlatiSagC and she said like welL the more volt go supposedl
22 the more he like expects and starts flirting 'a tilt girls and
23 that's what kind of like scared mc.
24 Q Okay. I've interviewed other girls and they've
25 tO:d inc pretty much the same thing about the massage but
Page 3
1 information and we arc conducting an investigation. We were
2 here last night, spoke with your mom and dad. If you can
3 just start from the beginning as to how you met him.
Okay
And how came about.
A
(Audio 1:26)
: 7
Page 5
1 might want to give a massage and I said I don't know. Then
• 1
heasked rite about what 1 wanted to do when I grew up and
3 stuff like that and I asked hint what he did and he said he
4 was like a scientist basically
5 Q Okay. Did he ever ask you how old you were?
A No. (Audit) at 4:08)
Q No. Did he know that you were 17?
A No, I don't think so.
9 Q Well it would have he= 16 lin 'a-as a vein. ago,
10 right?
11 A Well it like was ttlmost a year ago. (Inaudible)
12 17.
13 Q Okay. During the massage did you -- were you
14 naked or --
15 A No. I had Inv clothes on
16 Q You had all yi)ur clothes on?
17 A 11h-hoh.
18 Q Okay. Did he touch you in am, w ay?
19 A He was like kind of like caning towards it but I
20 was like you could tell I was shy so I think that's why he
21 didn't try. But 1 het:rd about other girls that he -- that
22 he got flirtatious with them and he made them take off ['left
23 clothe); and stuff.
24 Q Okay. What -- that was the first lime you went,
25 right'?
2 (Pages 2 to 5)
02421
HOUSE OVERSIGHT 012360
A Yeah.
".? Q Okax .
3 A wa. ito. II was the second nine that I gave him
4 a Massaw. The first time I went up with
5 Q Okay. You went upstairs with
6 A No, I was in the kitchen.
7 Q \rim Were in the kite-hen. That was -- you only had
8 two limes that you went there?
9 A Yeah.
10 Q The first time von didn't do anything but just sit
11 in the kitchen?
1? A Yeah.
13 Q Who did you sit in the kitchen with?
14 A I le had a cook that was there and he had -- there
15 was like two other girls there that live with him.
16 Q Okay. Did you massage his back? Was he naked
17 w lien
you were iiiiissriging liii ii?
18 A Well, lie had like a towel around Ins -- his upper
19 was (inaudible) but he had like a towel around him.
20 Q Okay. Did he ever remove that towel'?
21 A No.
22 Q When you were massaging him he never removed the
23 towel?
24 A No
25 Q Okay. Did you -- did he have you touch his
1 L?
2 A No
3 (,) No I have to ask.
Was=one of the two girls that was in the
5 kitchen NvAllyraf?
6
8 A Well, I just went there twice.
9 Q Right
10 A After that
Q After that you've never come back? Never went
12 back?
13 1low much did you receive for the massage?
14 A 'Iwo hundred.
15 Q You received 200. (Audio at 7:43)
16 Okay. Did=explain to you whai was going to
17 be involved?
18 A She said the first time you go there you pretty
19 much just give a massage, but the more you go there like the
20 more he expects. And that's it. That scared mc.
21 Q That's what scared you'?
22 BY DEFECTIVE DAWSON:
23 Q Did she sax' (inaudible) or did she (inaudible --
24 A Say didn't have to say it exactly but she implied
25 like, you know, like taking your clothes off and !initial:
Page
Okay. I lave you received any massage training'?
A Yes.
Q Okay. I lid you ever go back to his house'?
8
1 private area?
2 A No. No. I wouldn't do that.
Q You wouldn't do that?
4 Okay. Did he touch you in your private area?
5 A Ni. No.
Page 7
(Audio at 5:50)
6 Q No.
7 A I le kept like staring mine and like. I don't know,
8 I just felt uneomfortahle and I left. Ihrt I heard other
9 stories that like --
10 Q Right. Pin emcerned with on I know abtsit
11 other stories and I've interviewed other people have told me
12 different things. That's why I'm trying to find out what
13 happened hi ion. Okay'?
14 A h-huh
15 Q You're the VielMi 111 fills so thireS why 1.11111-yille
16 to lid out what happens to you.
17 A Oh-huh.
16 Q Okay? Who took you upstairs to the room'?
19 A This girlMthat lives with him.
20 Q Okay. Si) =took you up?
21 A Yes.
22 Q Did she tell you anything? Did she say anything?
23 A I huh-huh, 'lhere's a massage table and she just
24 laid a towel down and she said that Jeffrey will be out for
25 his massage.
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Page 9
1 that.
9 I3Y DI RECAREY:
3 Q Okay. So you didn't remove any of your clothing?
4 A No
5 Q What V\ ere you wearing? Can you remember'?
A I t. 10111 kni tV It  was a long lime ago. I don't
7 remeillber exactly.
8 Q ( )Lay .
A I don't w ant to tell you wrong.
Q I know. And I know you already told your mom what
happened. And like I said. I know this is hard far you
but...
A I was just seared. I just didn't w ant my name to
like --
Q Don't worry. You're not the only person I've
talked to. Okay? There's a lin of people that I've talked
to and I'm going to talk to.
I low did you get to his house'?
A With
Q I laley. took you the first time and you sat
in the kitchen.
A Yeah,
Q What about the second time?
A The second time I drove and she came with me.
Because I didn't want to --
3 (Pages 6 to 9)
02422
HOUSE OVERSIGHT 012361
1 Q
2 A
3 Q
4 A
6
7
8
9
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1_6
A
You drove.
Yeah.
Okay, What is it you drive?
I used to have a Cavalier.
A Cavalier. What color?
Red.
Q Okay. Can you describe to me ‘aat M,. Epsteiu
looks like? Jeffrey, looks like?
A He's tall and he has like greyish/black hair and
hc usually wears like glasses and he has blue cycs.
Q Okay. When you massaged him, von massaged his
back area'?
A Yes. And I did his feet be.
Q And his feet. Okay. Did you do his legs?
A Yeah. like his calves.
Q His calves. Thigh area'?
17 A No.
18 Q No. His chest area?
19 A No.
20 Q No. Can you desci ibe what his body looks like'?
21 A He's not fat but he's not like thin. He's like
22 normal like average.
23 Q Average? Okay. Is he hairy? Is he not hairy'?
24 A A little bit.
25 Q A little bit'? A little bit he's got hair on his
Page I
I back?
2 A Yeah.
3 Q Yeah'? How about hair on his chest?
A Lim --
5 Q You don't remember? Okay.
He did not (ouch you inappropriately'?
7 No.
8 No. Did he masturbate?
9 No.
10 • No. Do you know what masturbate means?
11 Yeah.
12 • Okay. Why don't you tell inc what it means just so
13 I know so you know.
14 A Playing w ith yourself
Q Okay. Okay. I have to make sure you understand
16 %%hat it means.
17 A Yeah.
18 Q Okay'? I know it's difficult.
1 9 He didn't touch himself --
20 A No.
21 Q while you were massaging him?
22 A No.
23 Q No. Is there anything else you'd like to add'?
24 A No. I mean I heard of other stories that he did
25 and I don't think it's very like appropriate like
.....
A
Q
A
A
Page 12
Q Right
2 A -- the stories that t heard.
3 Q Right Well. a lot tit people that I've been
4 talking to aic about your age and a couple younger than you.
5 St) that's the part that I have serious problems with.
6 A Yeah.
7 11,.(1:11V1-: RECARFY Do you have sly
8 questions'?
9 1W DETECTIVE DAWSON:
1C Q Did you sec am others -- when you vere there you
11 said you talked to two girls in the kitchen. The second
1 2 iliac VOLI 0 Lilt. Viii! ‘Veni jai --
.13 A 1 laley.
14 Q Ilalcy. Were there any other girls there?
15 A Yeah, there were the same two girls that were
16 there.
17 Q Same two girls? Okay.
18 A I'm rretty sure they like live and travel with
19 him.
20 RF.CAREY: Okay. All right. Well
21 at this time I'm going to conclude this statement.
22 Its 11:45 a.m.
23 (Thereupon. the interview ended.)
24 - - -
25
Page: -13
. . :!:! ......
4 (Pages 10 to 13)
02423
HOUSE OVERSIGHT 012362
TAB 10
HOUSE OVERSIGHT 012363
Page 1
IN RE: JEFFREY EPSTEIN
DRAFT
VIDEOTAPED INTERVIEW OF
02528
HOUSE OVERSIGHT 012364
(.1.herotillon, the rollowing videotaped interview "a3
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3 - - -
4 13Y )ET1'.CTIVF. lCAREY:
5 Q All right. I appreciate you coining down again.
6 All right. The reason why I asked you to come down was that
7 I'm investigating a case in which my investigation. I
8 believe that you have information on Jeff Epstein. Okay?
A Okay.
Q First of all, iiefive we even begin, lvi me Just
swear yOU Ill. Okay? Raise Your right hand for me. J )o You
swear to tell the truth, the cc hole truth and
nothing. but Ate truth so help you God?
A
A
Q
A
Q
A
Q
A
A
Yes, I do.
Okay. Do von Understand What I'm saving?
Yeah.
knoyx you're J-41Janish.
I know Yeah.
I can speak Spanish.
Yeah.
All right. First of all: do you remember Jell?
Yeah.
Okay. Lives on1113rillo?
(No audible response.)
Okay. Why don't you tell me from the beginning
Page 4
couldn't take inc.
2 () Oka\ .
3 A
4 Q Okay. Okay When you got there. \vital
5 happened?
6 A It seems really weird, the whole situation. 'there
weiv more girls in the house and then they just saw me go
8 ii 15151 the show mc the room, it was a massage rOOTII.
9 Prel ty nonnal Then he came and_ you know, l give him a
10 massage.
11 Q I Actiy. I've talked to a lot of girls and it lot of
12 girls have told me different things.
13 A 111/-huh.
14 Q 010Y.1) So I'm very aware of what happens when you
15 provide a massage. Okay'?
16 A Yeah
17 Q When you got to the house you went there with
18
19
2C
21
22
23
24
25
A Yeah.
Q Okay. I low did you come into the house? Do you
remember?
A What do you mean'?
Q Did you go into the front door?
A Yeah.
Q Did you come through the garage'?
Page 3
1 how You met Into.
2 A Okay. It Was something in higli school. I Ivery body
3 was like trying to make money and at the time I had two jobs
4 I guess. That was like two years ago.
Q About two years ago?
A Yeah.
Q When you first met him?
A No audible response
Q t )ktic
10 A Yeah F WilS 17.
YML 'acre 17 Ilicin?
l 2 A (Video at 1:37)
13 Q What is it that You c‘ere told you would have to
14 do?
15 A (-jive him a massage
16 Q Okay.
17 A Thai was it
:18 Q Okay Who took you there?
19 A Her name is
20 (1 Al ;1 Aldo
von have inly rOTTllal
21 massage training?
22 A No.
2.3 Q NO. Did -- so =took you there.
24 A MI didn't take me there. look one olmy
25 Ii tends and then Faith was the one who took me because=
5
6
8
9
had;)
Page 5
A Well, when you go inside there's like a door. I
2 don't know if it's the front door. I don't know.
3 Q Is it a wood door?
A A wood door, yeah.
5 Q It is a wood door?
A It's probably the back because it goes through the
7 kitchen.
Q It goes through the kitchen'?
9 A Yeah.
10 Q Okay. And you were brought into the kitchen.
11 right?
12 A Yeah.
13 Q Who was in the kitchen there?
14 A Oh. my God. it's so long ago.
15 Q So long ago?
16 A Yeah.
17 Q Okay.
18 A I don't remember.
1 9 Q Do you remember any of his assistants?
20 A
21
22 A She sc as ihe one.
23 Q She Was the one that you met with'?
24 A And there was the one that call me andl told her
25 I wasn't going to do it anymore. I think her name was
2 (Pages 2 to 5)
02529
HOUSE OVERSIGHT 012365
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95
M6Q) Okay So when you wine mto the house:
you go tnto the -lichen, you meet with sonic people there who
takes you up --
A With
Q You met with =*?
A Yeah. Theiity sit down and tell sit down
and everything I go and call Jeffrey. That's what I wins
coin -used when you say Jell. I don't know any Jeff And
then she takes me upstairs and=tays there and Faith
stays there like the lime whil717 upstairs
Q Okay Okay. SiM takes you upstairs. Did
You use the stairs --
A Yes.
() -- to go upstairs?
Okay. Do you recall anything lNeird w hen on were
going up the stairs'?
A 'he pictures.
Q Okay. Pictin es of what?
A Naked people.
Q Naked people. Okay. Okay. She brings you into
this you said it was a massage room'?
A Yes.
Q Is Jeffrey already there?
A No.
Page t-.•
1 Q his back aild on his legs. Okay I low \vete you
2 dressed when you were giving the mitssagc."
3 A 1 w as in leans and a .f -shirt
Q Okay. Okay.. At aoy point did he ask you to
5 remove your clothes?
6 A Yeah
7 Q Okay.. This is during the first massage'?
8 A Yeah And I say no.
9 Q And you said no. ( /Kay. Okay 11ti you continue
10 with the massage?
11 A Yeah ti was kind of weird that he asked me take
12 My clothes Off.
-3.13 Q Okay. So take me through then lion there. You're
14 doing the massage?
15 A I do the massage. Aker I firusIt he's like okay.
16 Actually lie pay me before I start doing the massage
17 Q Ile paid llow much did he pay 1:01I?
18 A S2tiO.
19 Q 1;200. At any Lime during when you're giving him
20 the massage; did he ever trim over --
21 A Yeah.
22 Q -- onto his back'?
23 A Illt-huh.
24 Q Okay. Tell me what happened alter that.
95 A I massage like on I don't know how you say it.
Q No? Winn did you do nest?
2 A I sit down there and she tells Inc just Wil il a
3 second. Then she comes back and we put like the little bed
4 for the massage and she's like okay, there's SOMe lotions
and he'll be right out
6 Q Okay.
7 A Then he comes in, he a like okay_ Then he k.nows
my name already. I'm Ihen he's like okay, just a
9 massage.
1 Okay. WIlell he Caine 111 lVati Ile M a I01.‘eP WIIN he
11 in a robe'?
L2 A No. He had like clothes. Ile was miming or
13 something like that.
14 Q I lad regular clothes oil?
L5 A Yeah.
16 Q And he got on the table with the clothes on'?
17 A No. He took his clothes off and he puts like a
18 towel.
19 Q Ile put a little -towel over hint Okay. So at any.
20 point did you sec him naked?
21 A Not on the first time.
22 Q No. Okay. So he lays on the bed, massage bed
23 with his towel and you start massaging hint. Do you remember
24 where you provided the massage?
25 A On the back and his legs.
Page 7
Page 9
1 Q in his chest area?
2 A C hi his chest. yeah.
3 Q During the time you're massaging lUrn on his chest:
4 is he touching Itinnselr?
5 A Yes.
6 Q t &ay. Explain, explain tItat to me.
7 A Well, he start getting a little excited about it
8 :aid he start touching himself and I told him stop. ;aid that,
9 that was it.
10 Q >Lay. When you mean by touching himself. you mean
11 he IN us masturbating'?
12 A Yes.
Q And You told him to stop?
14 A No I didn't tell him to stop.
15 Q I. okay. Okay. So while you're rubbing his
16 chest, did he ever take oil his towel?
17 A Ni
18 Q So how would he he able to masturbate Jr--
19 A Welk like lie had his hand under the towel.
20 Q Under. So you never saw him. Did you exet see
21 him naked?
22 A No. Not the first time hut I saw him like the
23 second time.
24 Q okay. Okay. Okay. So then you did your ma --
2 5 continued with Your massage?
3 (Pages 6 to 9)
02530
HOUSE OVERSIGHT 012366
1. A Yes.
2 Q Okay. What clsc happened alter that?
3 A Nothing elsc. After I was finished. Acnizilly
4 like it was supposed to be an hour. But the first time it
5 was just 30 minutes.
6 Q Okay. The time you were rubbing his chest and he
7 was masturbating, did he ever elimaN?
8 A No.
9 Q You know what I mean by that?
1 0 A Yeah.
11 Q Okay. How did you cad the massage? Did he just
12 say that's enough?
13 A Yeah.
1 4 Q Okay. Okay. So then you went back downstairs?
A Yeah. And I say toMinkay.l'in done, and we
16 left.
Q Okay. Did he ever ask you to leave your telephone
8 ntimber to call you back if you wanted to work?
19 A He asked for my phone number.
20 Q He asked for your phone number?
21 A Yeah.
22 Q Did=give him your phone number?
23 A (Nods head yes.)
24 Q Okay. Did Mget paid for taking you'?
25 A Yes.
Page 12
go to go work.
A Yes.
Q Okay. The same thing, you go into the back door
4 to the kitchen area?
5 A Oh-huh.
Q You meet with=
A Yeah. And she takes me upstairs.
Q She takes you upstairs. Okay. He offered you
9 more money to get naked?
10 A Yes. Well, he told mc just to take my shirt off.
11 He didn't say anything clsc.
12 Q Okay. Okay. And did you?
13 A No.
14 Q No. But that's not the only two times you'd gone.
15 You've gone more times'?
1 6 A It was like around three, four times and then I
17 just --I was just scared that he was gonna do something.
1 8 Q Did he ever photograph you'?
19 A No. Not that I know,
20 Q Did he ever take videos of you?
21 A No.
nn Q Okay. Did you ever give the massage with any
23 other woman?
24 A No,
25 Q Okay. Did you ever get naked while doing the
Page n
Q Ilow 'ouch did she Oct paid'?
2 A $200
3 Q She gut paid S200 for taking you as well. Okay.
4 So tell toe about the second time.
5 A Second time1 don't rernerni-yer who took me I never
6 went by Inv self. I was seared to go but it was kind of like
7 ...le same. Same situation than the first one but he offer rue
6 more money just to lake my shirt off and I didn't do it rind
9 he Nlas the some. I le did the same things and then he took
10 hi; low el off
1 Okay.
12 A And like after he was done like he never like got
1 .3 to the climax. I never saw him.
14 Q You IleVet SM..
15 A (Shakes head no.)
16 Q Okay. You o ere going U.
17
18 A Yeah. That's how everything started.
19 Q ihuits boo everything started'.'
20 A 11allof the school knew about it.
21 Q flail of the school knew about it? Let me, let me
22 back up for a second. You go the second time. Who calls
3 you to go back to house?
24 A
25 Q calls you Novi you make an appointment to
Page 13
1 massage'? Any of the massages'?
2 A Once.
3 Q Once.
4 A But it xvas in my underwear. It was never
5 completely naked.
Q Okay. You staved in your Mixon'? I littler wear?
7 A And my top.
8 Q And your top So you staved in bra and panties'
9 A (Nit aIldible reSp011Se.)
10 )kaV.
11 A I think there w as one that I take :it). lira off hut
12 that was it.
13 Q Okay. And each time you went did he offer you
I 4 more monies to do mole tInugs'?
15 A Yes, Actually I knew that because of she
1. naudthle). I don't know her Iasi name.
17 Q okay.
18 A 13ccau.se site ask me, she says he'd offer more money
19 if I have sex with him and I said that's never going to
20 happen. 'there's no way IM going to do that for money.
21 Q Okay. And by having sex means intercourse or --
22 A Yes. I guess. I don't know. I don't like talking
23 about
24 Q Okay. 'line second time, did he offer you more
25 money to do more things')
4 (Pages 10 to 13;
02531
HOUSE OVERSIGHT 012367
)RAF_
A Q   Yeah. $100 more just to take iny shirt off Okay. And you said you didn't do it.
3   A   No.
Q   Okay. Did hc masturbate on the second time?
5   A   Yeah.
6   Q   And did he ever climax?
7   A   Actually the second time like it wasn't that bad
9
10
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14
15
1.6
17
JR
.L9
20
21
23
24
25
because he Nvas like on the phone all the time and so he
wasn't paying attention to what was going on.
Q Did he ever at any point masturbate the second
time?
A No. Not that I remember.
Q Did he ever ask you any questions or speak to you
or ask you anything?
A Well, he tried to talk to you just to make you
comfortable with thc situation like where do you work and
like how much do yon make at your work and then he start
saying you can make more with we. but I didn't feel like it
was right.
A
A
A
Did he er.er know your real age?
After a while like because somebody told him.
That you w ere --
Yeah.
17'?
Like told us_ we were supposed to say wc
Page 15
1. were 18.
2 (.,? Arid who 11)1d 1oil that to say that'?
3 A
4 Q
5 A was the one who broug.lu everythtng to
6 everyone at school. That's how we know about it. Then she
t()ok=und =took me. .fdltitilio 15:02)
8 Q I )kay. So each time nit did go, did =get
9
10
11
13
ii 4$, reilmioinigivaiL
16 A
.................................................................................. i3tilldidn't get
18 money out of that.
19 Q Okay. Did anybody ever help you do a nias.,;age with
20 hint?
21 A No.=isked me to do it with her and I didn't
22 feel comfortable.
23 Q All right. All right. Talk to me about the third
24 time you went.
25 A I don't remember it was like kind of always --
(Video at 1-1:57)
looney fol
A Well. went oith mehlice I guess. And that
was it. Then I went n, ith
Q Okay. And did she make money? 1)id =make
for taking you to him?
3
4
5 he paid you more to do more things. right?
6 A Yeah. The thirdlime it was when I took my shin
7 off.
8 Q Staved with your bra or were you --
9 A Stayed in my bra
10 Q Okay.
11 A And that was when he paid me 300.
12 Q He paid yon 300 for that'?
13 A Uh-huh.
14 Q And same thing --
15 A Yeah.
16 Q He came ill. Was he naked again'?
17 A Yeah.
18 Q Okay. You gave hint a massage and at that point
19 was he still playing with hi insell?
20 A Yeah.
21 Q Masturbating?
22 A Uh-huh.
23 Q Okay. Do you know if at any point did he ever
29 climax during this'?
25 A No.
Page 16
it was always -- It was the same_
2 Q ti was the same?
A It was the same.
Q Obviously more stuff happened because, you know.
Page 17
1
2 say that's it, that's enough?
3 A Yeah, he would just stand up and take a shower and
4 I unild grab my things and leave.
5 Q May. All right. Talk to me about the pail when
6 von got diiwn lii votir underwear
7 A That was the last time that I saw han.
8 Q When was the lust time? Was that --
9 A It w as 'mg ago. M4we than six month:•tago.
1.0 Q You sure it's not any lime sooner than that?
11 A I don't remember I ike I told I didn't
12 want to do it anymore I was scared he was going to do
13 something_
14 Q t )kay Why do VI KI sa yr itt ii ere scared he was going
15 to do sornething-.'
16 A Ikeanse I like know he has a lot ur girls and I
17 don't know, like he was olIering=inore money for it.
18 Like I think he bought her a car or something like that.
19 She Just got a car and she told me he got it for her.
20 Q Do you know what kind of ear it was?
21 A I think it's a Dodge or something.
22 Q A Dodge"
23 A And then she like then had money or anything and
24 she ended up going to Europe for like the summer.
95 Q Did she go with Inin?
Q Okay. I IUNV 1‘1/1.11d the in issages end" Would he Just
5 (Pages 14 to 17)
02532
HOUSE OVERSIGHT 012368
11)
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13
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15
16
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19
20
21
22
23
24
25
1 A I don't know. We never talk about it because I
2 was -- I didn't like the whole situation.
3 0 Okay. Did he ever touch you?
4 A Yeah.
5 Q In what way.?
6 A My hack and my butt.
7 Q Did he ever, did he ever take out any toys?
A No.
9 Q Did he ever touch your breast area?
10 A (Nods head yes.)
11 Q Did he touch your vaginal area'?
12 A Yeah.
13 Q All right. Did he touch you with his hands or
14 with something else?
15 A With his hands.
16 Q Okay. Okay . Was this over your underwear or
17 under?
1.8 A Over my underwear.
19 Q Over or under?
20
2]
22
2.3
24
25
A Over.
Q Over. Did he ever insert his fingers in you'?
A (Shakes head no.)
Q And as he was doing this, he was paying more
money?
A The maximum that he paid me was 300.
Page 1 9
Q Three hundred. And that was the last time you
2 went?
3 A (Nods head yes.)
4 Q When he touched your breast area you didn't have
5 a bra on'?
6 A I didn't have a bra on.
Q You didn't have a bra on. And your buttocks?
8 A Uh-huh.
9 Q Was that over your panties or under your panties?
A Like I have a thong on so...
You had thongs. Okay . All right. Did he pull
you close to him?
A Yeah.
Q And all this while hc was masturbating'?
A (Nods head yes.)
Q Did he have you touch him?
A No.
Q Aside front the massage. touch him in his penis
area?
A I Iuh-huh. No.
Q Did y.ou bring anyone else other than --
A
A
(Video at 20:22)
Do you know last name?
2
3
5
-7
8
9
10
11 Q Did you ]uccive luoucy forM or --
12 A I don't remember. I'm pretty sure I didn't.
13 Q Okay. When was the last time you had contact with
14 anvone from the house?
15 A Wel1,1 don't know because she told me they were
16 going to New York the last lime we talked. the last limel
17 went.
18 Q What's a while ago'?
19 A Probably two months or more.
20 Q Who called you?
21 A
23 A And she said that she was going where?
I hey were going to New York.
24 Q New York? Nobody else from the house has called
25 you to say the police are looking into it?
A
A
A
A
No. No idea.
lotA about•
Does she also go to
1111-huh.
And \vital about M?
Yes.
Did von receive monies for taking =mil
Page 20
Page 21
1 A (Shakes head no.)
2 Q Okay. This case is basically an investigation, an
3 open investigation, so I appreciate it what we discuss stays
4 here. Okay?
5 A 1th-huh.
6 Q Don't tell anybody that we. that we talked ()km-)
7 A )kav
8 Q Did y ouel.er have any intercourse with him?
(Video at 22:41)
1'-'10 A Nr (tl, orar?
11 A i Shakes head no.)
I 2 Nothing?
13 A Nothing else.
14 Q C /Lay. I'm going to show ymi mi group of
15 photographs. I'm going to show yon a group of sms
1 6 photographs. Oka '? I'm trying, trying to see if thisM
1 7 is in these six photos. Okay? 11's important that you look
18 at all six of them and be sure who you pick as the person as
19 =, okay? She may or may not be in these six photos but
20 it's imrx tam foi you to pick the right one. Okay?
21 A 1.1h-huh.
22 Q Take your time looking at those six photos there.
23 A l don't see her.
24 Q She's no: in those photos there?
25 A No.
6 (Pages 18 tc 21)
02533
HOUSE OVERSIGHT 012369
tr________________
I Q Him. would you describe 1)RA
1 appreciate you coming down. Okay?
2 A She would be here but she'.  :she's= A Thank you.
3 and slit, looks like her hi it I'm not •.tit-L: 3 0 All right.
4 Q Okay. That's why I needed you to be ribr'lutel 4 (Thereupon_ the interview ended.)
5 sure. I appreciate you being hifflest and not picking anyone 5 - - -
out bee:11.3tie i hat's important You know'' You have my card, 6
7 right?
8 A No, I lost it. lake I think I left it at my job. 8
9 Q Okay. I gave your sister one. Thai's MY enrd. 9
10 A You +vent hack 10 ms house? 10
Q Yeah,11.vent by today. She's the one ho gave MC 11
12 your cell. Your sister 12
I 3 A You tell her what it was? 13
14 Q No, No. I just told her thatt.ou were a witness 14
15 and I needed to talk to you. 1 .`)
16 A Is he going In know ally thing about any ()I this') 16
17 Q About the investigation? Fvent natty I'm sure he 17
113 ;111irl 1 1 1;; 1.1
W,.. out about the investigation. . would appreciate 1 fi
19 it if anyone did contact you that you call me and give me 19
20 JUSt -- basically let me know that somebody called you. 20
71 A If they call me?
22 Q If they call von. Is there anything else you'd
23 like to add to this statement or -- 73
24 A No. just seared that he's gonna knots
25 Q Why are you scared of him'? 25
Page 23
1 A 'that he's gratin) tlo something.
2 Q Trot gonna do am. thing.
3 What did he tell you he did for a living?
4 A Ile was in brain something. I le studied the brain.
5 Q 1-le's an investor and that's it. Just a money
6 investor That's it les unit -- hall of ilie thmes that
7 lie to.c.H  some of these people, he's just a money invcsiiit.
8 That's it. So don't be afraid. And if they do call you,
9 just cull me and let me know
10 A If they ask me to come over there should I just
11 say no? 1. ike I don't Ns ant to go
(3 You haven't been there?
13 A (Shakes head no.)
i'iwt When .s 1.11.2 ,USt time ou said you were there?
lb A I.ike three_ four months ago. Longer than that. 1
1 C. don't remember.
17 Q I think it's about three or lour months ago. I
18 think it's three or hour months ago because -- is there
19 anything else you'd like to add?
20 A Not neal l\ .
Q No? Okay. 1 appreciate you coming do;wn. And let
22 me walk you out.
23 A Is something going to happen to me'?
24 Q No. No. I just, like I said, you're not in ;Inv
25 trouble whatsoever. I just wanted to talk to you. I
Page 24
Page 25
(Pages 22 to 25)
02534
HOUSE OVERSIGHT 012370
TAB 11
HOUSE OVERSIGHT 012371
U.S. Department of Justice
Office of Legislative Affairs
Office of the Assistant Attorney General Washington, D.C. 20530
November 9, 2007
The Honorable John Conyers, Jr.
Chairman
Committee on the Judiciary
U.S. House of Representatives
Washington, D.C. 20515
Dear Mr. Chairman:
This letter presents the views of the Department of Justice (the Department or DOT) on
H.R. 3887, the "William Wilberforce Trafficking Victims Protection Reauthorization Act of
2007," as introduced by Congressman Lantos on October 18, 2007. The Department has
significant concerns, which are detailed below in a section-by-section analysis. The proposed
legislation, as drafted, would eliminate the Department's role in several important steps in the
victim identification process, and thereby negatively impact our ability to ensure the safety of
victims and their families, rescue additional victims, and apprehend and prosecute human
traffickers; it would broaden the criminal statutes regarding prosecution in a manner that detracts
from effective enforcement efforts and raises serious federalism implications; and it would
unconstitutionally intrude into Executive authority.
1. Section 102
The provision in subsection (e)(2)(B) authorizing the Director of the Office to Monitor
and Combat Trafficking in Persons (G/TIP) at the Department of State to interview victims
should clarify that the Director is authorized to do so only with the consent of the Attorney
General in any case where an ongoing investigation or prosecution may exist. Otherwise,
serious issues could arise that would complicate or even scuttle prosecution. For example, any
statements made to the Director would presumptively have to be turned over to the defense and
any statements that contradict statements made to law enforcement or prosecutors would be
required to be turned over to the defense.
2. Section 103
DOI finds section 103 unnecessary and duplicative of existing efforts and, therefore,
opposes its inclusion in the bill_ DOJ and other Federal agencies are already offering the types
of assistance that are described in the section. Furthermore, the new subsection (a)(i)(3) would
require the United States Government to provide "technical assistance to provide legal
frameworks and other programs to foreign governments and nongovernmental organizations to
HOUSE OVERSIGHT 012372
ensure that foreign migrant workers are provided protection equal to nationals of the foreign
country." This provision does not differentiate between legal and non-legal migrant workers, nor
does it distinguish between forced labor and non-coerced migrant labor. DOJ believes that any
international standard that we promote must mirror our domestic standards. Similarly, the new
subsection (a)(i)(4) could be read as encouraging countries to loosen their immigration Iaws,
'something that the United States Government might not be willing to do.
Subsection (b) amends the Foreign Assistance Act of 1961 (22 U.S.C. § 2151 et seq) to
provide specific assistance for anti-trafficking investigation and prosecution units in foreign
countries. This subsection could be construed as prioritizing sex trafficking over labor
trafficking. As stated above, DOJ believes that any international standard that we promote must
mirror our domestic standards, which prioritize both sex trafficking and labor trafficking.
Further, the amendment to 22 U.S.C. § 2152(d)(a)(2) should include a reference to labor
trafficking and should, therefore, read "including investigation of individuals and entities that
may be involved in trafficking in persons involving sexual exploitation or forced labor."
3. Section 104
The Department objects to the language in this section that specifies the groups with
which the United States Government must consult and coordinate in offering assistance and
protection to victims of human trafficking. Such language both places undue restrictions on the
United States Government and could limit the Government's ability to deal with some necessary
groups. It has been the consistent practice of the Department to consult widely with a range of
stake holders and others before designing a program of foreign assistance on human trafficking.
Such an additional requirement in the statutory language is unnecessary. We suggest that the
language be amended to read, "[l]n cooperation and coordination with organizations which may
include the [UNHCl2], the International Organization [for] Migration, and other relevant
organizations...."
4. Section 105
DOJ recommends that subsection (a) also require that the effectiveness of assistance
programs be measured based on best efforts to facilitate cooperation with law enforcement, along
with the other criteria.
5. Section 106
DOJ opposes the bar in subsection (b)(1) against including cases in which probation or
low sentences are given. Some of the most important cases are the ones against cooperating
defendants that result in minimal sentences in exchange for information or testimony. Embassies
should have the discretion to take such situations into account when evaluating foreign
government efforts to combat trafficking. The Department recommends amending section
(b)(1 )(B) by striking "shall not be considered to be an" and inserting in its place "shall be
considered on a case by case basis to determine if it will be considered an" so that it will give the
Secretary of State greater flexibility in evaluating the efforts of other countries.
2
HOUSE OVERSIGHT 012373
The Department also objects to the new paragraph (11), which lists as a criterion for
ascertaining whether the government in question has made "serious and sustained" efforts to
eliminate trafficking "[w]hether the government has made serious and sustained efforts to reduce
demand for commercial sex acts and for participation in international sex tourism by nationals of
the country." We object to this language because it is vague and will, by implication, require the
United States Government to evaluate itself under this "serious and sustained" standard. The
Depatiment prefers the language that was added by the 2005 reauthorization of the Trafficking
Victims Protection Act, which evaluated whether countries "adopted measures" to reduce
demand.
6. Section 107
Section 107(a) of the Act raises separation of powers and Chadha concerns. Section
I07(a) would add a new 22 U.S.C. § 7107(b)(3)(D), which would limit the amount of time that a
country could remain on the Tier IT Watch List to two years, "unless the Secretary of State
provides to the appropriate congressional committees credible evidence that" the country had
taken certain steps to make significant efforts to counter trafficking. That provision further
requires that "[s]uch credible evidence" shall be provided to Congress in a report.
To the extent that section 107(a) purports to give congressional committees authority to
determine whether the Secretary's decision to exempt a country from the watch list is based on
sufficiently "credible evidence," the provision would give the committees a role in executing the
law that the Constitution does not allow. "[O]nce Congress makes its choice in enacting
legislation, its participation ends. Congress can thereafter control the execution of its enactment
only indirectly—by passing new legislation"—that complies with the bicameralism and
presentment requirements of Article I. Bowsher v. Synar, 478 U.S. 714, 733-34 (1986); ,sree also
NS v. Chadha, 462 U.S. 919, 951-52, 958 (1983). To avoid this concern, we recommend
replacing "provides to the appropriate congressional committees credible evidence" with
"determines;" and replacing "Such credible evidence" with "Such determination."
7. Section 108
DOJ opposes the requirement in section 108 to create a database "combining all
applicable data collected by each Federal department and agency represented on the Interagency
Task Force to Monitor and Combat Trafficking." The database would contain law enforcement
sensitive information, which would prevent the data from being accessible to non-law
enforcement agencies, many of which are a part of the interagency task force. Furthermore, such
a database would be difficult to create, particularly within the timeframe provided in the statute,
because it would require information from multiple agencies that collect data in varying forms
and levels of specificity.
8. Section 109
This section authorizes the President to establish an award for efforts against trafficking
and directs him to establish procedures for selecting recipients of the award. DOJ opposes this
provision, as it interferes with the President's policy-making authority.
3
HOUSE OVERSIGHT 012374
9. Section. 110
The Department opposes the statutory language in subsection I 10(a)(1)(B) that
specifically mentions the U.S. Government sponsored hotlines for reporting instances of
trafficking in persons. Statutorily providing for the names of the hotlines would interfere with
the President's policy-making authority to change the hotline structure at a later date.
Furthermore, the Act, as written, misnames the hotlines.
10. Section 201
In section 201, the Department objects to the new subsection "(bb)." To the extent that
such a subsection is necessary, a question that we defer to the Department of Homeland Security
(DHS), the decision regarding cooperation should include the Attorney General in addition to the
Secretary of the Department of Homeland Security, as it does in Section 201(b).
DOI. defers to DHS in regard to subsection (a)(1)(E), although we would note that by
removing the "unusual and severe harm" standard, victims will be eligible for a T-visa upon a
lower showing of "extreme hardship."
The Department also defers to DHS in regard to subsection (a)(2), which would extend
T-visas to parents and siblings of trafficking victims. As a factual matter, however, the provision
should be amended to strike any reference to "as a result of the alien's cooperation with law
enforcement." Traffickers threaten victims to intimidate them into compliance with traffickers'
demands and to retaliate for victims' escape, not because of law enforcement cooperation. It is
counter-factual to describe the pattern of threats and retaliation as linked to law enforcement
cooperation, and disregards the fact that threats often only subside when law enforcement takes
measures to secure the family or punish the traffickers and their associates who threaten victims'
families. Furthermore, it is unclear whether the reference to siblings encompasses both minor
and adult siblings, and whether spouses and children of adult siblings would be eligible for a T-
visa.
In subsection (b), DOJ opposes the new subsection (8)(B), which grants sole authority to
the Secretary of DHS to consider whether "extreme hardship" exists. The new section, however,
also requires consultation with "prosecutors," which presumably refers to prosecutors at DOJ,
since DOJ is the lead prosecutorial agency for cases involving human trafficking. Since these
prosecutors are under the Attorney General's authority, the consultation requirement should
include consultation with the Attorney General.
Subsection (c)(1), which creates the new subsection (3)(A)(i) in section 107(c) of the
Trafficking Victims Protection Act (TVPA), should limit applications for continued presence to
those being made by "Federal" law enforcement officials. Limiting the applications to those
submitted by Federal law enforcement assists in the victim identification process. The
Department has established a memorandum of understanding with DHS that ensures that the
Department's prosecutors are informed when investigators apply for continued presence.
Furthermore, limiting the applications to those submitted by Federal law enforcement ensures the
uniformity of standards in making the determination as to whether an individual is a victim of a
4
HOUSE OVERSIGHT 012375
severe form of trafficking in persons and eligible for continued presence. Finally, Federal law
enforcement involvement in the process allows Federal prosecutors the ability to identify
patterns of human trafficking activity that might span multiple local law enforcement
jurisdictions. For these same reasons, the new subsection (3)(B) should add "Federal" before
"law enforcement" to limit the authority to request parole for relatives to Federal law
enforcement officials.
The new subsection (c)(3)(A)(ii) should add "endeavor to" after "shall" so that a legally
actionable obligation is not created as to Federal law enforcement's role in protecting the safety
of trafficking victims and family members. While the U.S. Government makes every effort to
protect trafficking victims, the statutory language, as written, could be construed to create a
legally cognizable right and could lead to litigation.
In the new subsection (c)(3)(A)(iii), DOJ opposes extending continued presence for the
duration of a civil suit. It also raises the potential for abuse because of the lengthy and
plaintiff/victim-controlled delays in conducting civil litigation. Furthermore, physical presence
in the United States is not necessary for the successful maintenance of a civil action. Victims
have other options to obtain status in the United States, such as T- and U-visas.
DOJ notes a technical change to subsection (d), which currently has two subsection (2)s.
DOJ recommends striking the second "(2)" and replacing it with a "(3)."
11. Section 202
The Department opposes the language in section (a) that legislates the existence of a
specific task force, such as the Trafficking in Persons and Worker Exploitation Task Force. DOJ
recommends deletion of this reference and the replacement of the named task force with "the
Attorney General."
DOJ also opposes the 120 day deadline in subsection (f) as unreasonable due to language
barriers and translation needs.
12. Section 203
In subsections (a), (b)(1-2), and (c), DOJ opposes the language removing the Attorney
General's role in determining whether the relevant applicant has complied with reasonable
requests for assistance, an important factor in the decisions regarding T-visas, and that the
investigation or prosecution is complete. Because the Department is involved in its prosecutorial
as well as its investigative roles, DOJ participation is critical in assessing assistance with law
enforcement, and it is well-situated to assess whether a victim has complied with reasonable
requests for assistance that went through investigative agencies outside DHS, such as cases
investigated by FBI or DOL. Therefore, a joint determination is appropriate because of the
number of different law enforcement agencies that may be involved in a particular matter.
5
HOUSE OVERSIGHT 012376
13. Section 205
D0.1 opposes the addition of the new subsection 240A(b)(6)(A) of the Immigration and
Nationality 21 Act (8 U.S.C. 1229b(b)) unless the word "Federal" is added before "law
enforcement official." The same proposed subsection currently states that the Secretary of the
Department of Homeland Security "shall grant parole" to the relatives of trafficking victims.
DOI. recommends changing this language to read "may grant parole" so the Secretary has the
latitude to make an appropriate decision. There may be reasons pertaining to the circumstances
of the relatives of the trafficking victim for which the Secretary should have discretion to deny
parole. Further, DOJ finds it necessary to strike any reference to "as a result of the alien's
cooperation with law enforcement" for the reasons noted above.
In subsection, (6)(B)(ii)(II), DOI opposes a statutory requirement that parole be extended
during pending civil actions. As indicated above, this action would create a potential for abuse
because of the lengthy and plaintiff/victim-controlled delays in conducting civil litigation.
14. Section 211
The Department opposes the change of the "and" in subsection (1)(A) to an "or." Both
the Attorney General and the Secretary of DHS need to be involved in the certification process.
The current certification process is well-established and needs no statutory revisions. DOJ also
opposes the change in subsection (1)(B), which would remove the Attorney General's authority
in stating whether a person's presence is necessary in ensuring an effective prosecution. As the
agency that prosecutes cases of human trafficking, DOrs involvement is vitally important. The
Department has the same concern with the proposed change in subsection (2).
15. Section 213
We strongly oppose the language in this section that inappropriately removes law
enforcement from any initial determination of victim status or benefits eligibility. DOJ and DHS
play a critical role in protecting the safety of victims and service providers. Any failure to
involve Federal law enforcement immediately upon suspicion that a crime has been committed
could threaten the safety of the victim, impeded efforts to promptly rescue victims still in
jeopardy, and possibly man that the offenders avoid apprehension. DOJ recognizes the
important of including HHS at the initial stages for the purpose of facilitating prompt delivery of
the full range of available benefits and services to trafficking victims. DOJ will continue to work
with DHS and BM to ensure that interagency procedures afford victims of trafficking prompt
protection and access to these services.
The Department further objects to the provision set forth in paragraph (G), which would
require both Federal and state law enforcement officials to inform the Department of Health and
Human Services (HHS) of the existence of a potential victim, but does not require HHS, other
Government officials, or non-governmental service providers to inform Federal or state law
enforcement of such a victim. To the extent that such a notification procedure must exist, it must
also include notification to the Attorney General and the Secretary of DHS, who bear
responsibility for prosecuting and investigating instances of human trafficking.
6
HOUSE OVERSIGHT 012377
DOJ also opposes subsection (b). Since the passage of the TVPA, DOS has been one of
the principal agencies conducting trainings for a multitude of audiences, including task forces
and Federal, state, and local law enforcement, on the issue of trafficking in persons. The
Department also has experience in conducting training on juvenile victims through the Innocence
Lost National Initiative. Effective efforts to combat trafficking must mobilize the expertise of
HHS, DHS, and DOJ.
DOJ also notes a misspelling in the new subsection (F)(ii)— "edibility" instead of
"eligibility".
16. Section 214
Section 214 of the bill authorizes the Attorney General to make grants to assist victims of
severe forms of trafficking up to $2.5 million in 2008, increasing to $15 million in 2011. The
Department of Justice already has authority to make grants for the provision of services for crime
victims and does so at a level in excess of $250 million a year. Also, the authorization of yet
another grant program runs counter to the Administration's proposal in the 2008 Budget to
consolidate DOJ's more than 70 grant programs.
Moreover, any provision purporting to expand or alter definitions of individuals of
qualifying for victim benefits must include the requirement that a Federal law enforcement agent
must declare the individual to be a victim of a severe form of trafficking in persons, and that the
victim agree to cooperate in the investigation and prosecution, or that the victim be under the age
of 18.
DOJ opposes the consultation requirement in subsection (a)(1) with the Secretary of State
for establishing programs to serve domestic, U.S. citizen trafficking victims. Such domestic
authority falls outside of the mission and expertise of the Department of State. DOJ also opposes
the mandatory consultation with non-government organizations (NG0s) regarding the provision
of services. This creates a conflict of interest since many of the NGOs will apply for and could
receive grants under the program. Finally, any section regarding the provision of victim services
must also contain language that includes organizations that provide services to "juveniles
subjected to trafficking, as defined in section 203(g) of the Trafficking Victims Protection
Reauthorization Act of 2005," which would ensure that the funds authorized to the Attorney
General for establishment of grants will go toward the work and development of the Innocence
Lost Task Forces.
DOS opposes subsection (b) because it provides Victims of Crime Act of 1984 funds to
prostitutes implicated in violations of the Mann Act (criminalizing transportation of prostitutes in
interstate commerce). Such persons do not meet the legal defmition of "victim" as that term is
defined in the law, unless the person prostituted is under the age of 18 at the time the crime was
committed or the person, through the application of another Federal statute or regulation,
satisfies the legal definition of a victim. Such persons are already eligible under the Crime
Victims Fund Act to receive benefits.
7
HOUSE OVERSIGHT 012378
Dar opposes section 214(d), as it could be construed to require the Attorney General and
the Secretary of Health and Human Services to make legislative recommendations to Congress in
violation of the Recommendations Clause. To avoid this concern, we recommend inserting ", if
any," after "recommendations" in section 214(d)(2)(E). Further, DOJ finds subsection (d)
redundant. A thorough study of services available to domestic and foreign victims was
conducted by the Senior Policy Operating Group in 2005-2006 and found few statutory
differences between the treatment of domestic and foreign victims.
Subsection (d)(2)(C) contains a redundant statement. Victims of sex trafficking are
victims of severe forms of trafficking in persons.
17. Section 221
In subsection (a), DOJ opposes the proposed change of MO*g thc içhw!edgc, of
AgOI0000000#0i010404:03 to:i',14Y.PF*Vir.,01go!,
This change of law would
create a strict liability crime, similar to 18 U.S.C. § 2423(a), with similarly severe 10 year
mandatory minimum sentence. However,16W04004kig44(a)**40#Xa) is exceedingly
.1iii*KtiiitifitAkt0A0t***.grilgOgogfogoo Therefore, the suggested subsection (a)
would create a rare circumstance wherein there is a substantial mandatory minimum sentence for
an already unusual strict liability crime. Accordingly, this provision is likely to face significant
legal challenges.
DOJ opposes subsection (b) in its entirety, The proposed language is both over-inclusive
and under-inclusive of human trafficking activities, and the language is vague. Moreover, the
provision is unnecessary because section 1589 already prohibits many of these activities when
they result in "serious harm," whether physical or emotional, to the victim.
The Department opposes subsection (0(1), which would expand the Mann Act to include
cases "affecting" interstate commerce. The Department does not require any additional statutory
authority or expanded jurisdiction in order to continue its successful prosecution of human
trafficking cases and related criminal conduct. Agrg#0.0,:01010::*:-which  ',!ktdtt*.-
!toiNio:: #.',g*aittatimoffdt0 :,„,i:::.:::: .t '
::44011i iri t.i-400:ifit
:•0I'11dLer1:ww: ?t. cruon is prLsunlcd, t e, .‘'11.:1#00i. ::= .04 0.00'
;00t,titjpqpqigiv '. aft Amol.t*  crvitude, rnd civiieroiatsi.x-411Y6.1Yillgi :all titta :D)i;:.i.AV
iiiiitt.-04t0i000704.0tkoi, The Department's record during the last six years demonstrates its success
in investigating and prosecuting trafficking and retated crimes and in convicting and securing
appropriate sentences for traffickers.
At efia historicali
'been prosecuted at the',igAtoxim,01.00.-i 'This allocation between state and Federal
enforcement authority does not imply that these crimes are less serious, but rather reflects
important structural allocations of responsibility between state and Federal governments. The
federalization of these crimes would treat them differently than other serious crimes such as
murder and rape, which are prosecuted at the state level. Kidnapping, similarly, is a Federal
crime only when it involves transportation "in" interstate commerce. .
8
HOUSE OVERSIGHT 012379
Departi state aid localator1tits are not eutrently
4
high volume of prostitution-related crimes,
and capacity to prosecute these offenses.
,00.0.74.;pmj§0043g*...pppggyo Finally, due to the
the Federal government lacks the necessary resources
Therefore, to the extent that this !!: 414 ...okikigrittliOigl
ti-000040!.
!ti.iAt:04.iilbiii:F000%).114*00000.000.Pt 0000Wittga4
DOJ also opposes subsection (g), which would expand the sex tourism offenses to
include those who travel for purposes of illicit sexual activity with adults. The Department's
current efforts with regard to extraterritorial offenses focus on child sex tourism, which are very
demanding and resource-intensive cases, requiring gathering evidence abroad, bringing victims
to the United States to testify, and coordination with foreign law enforcement agencies and
foreign governments generally, among other matters. Any expansion of authority would be a
distraction from those priority cases and would exacerbate existing burdens on investigation and
prosecution.
The Department believes that the addition of 18 U.S.C. § 2423A is unnecessary and that
18 U.S.C. § 2423 does not need to be amended.
Should Congress create 18 U.S.C. § 2423A, DOJ believes that language should be
retained in 18 U.S.C. § 2423(e) that allows the Government to charge attempt or conspiracy for
18 U.S.C. § 2423(a) crimes. Finally, DOJ notes that the definition of illicit sexual conduct
needs to be updated to include production of child pornography.
18. Section 222
As a general matter, the Department opposes the expansion of jurisdiction over offenses
involving non-American offenders or victims that are committed outside the United States. The
expansion ofjurisdietion in this section would place an enormous strain on available resources.
In addition, this new section's jurisdiction description overlaps with 18 U.S.C. § 3271. Should
the choice be made to keep the jurisdictional provisions provided for in this section, perhaps it
would be more effective to expand section 3271.
19. Section 223
These provisions are not directly related to trafficking. As this section is related to aliens
brought into the country for the purposes of prostitution, without a showing of force, fraud, or
coercion, and the International Marriage Brokers Act (IMBRA), this bill is not the vehicle for
this language. Furthermore, subsection (a)(1) removes the requirement from section 278 of the
Immigration and Nationality Act that such conduct be done in furtherance of the importation of
the alien. By removing this requirement, the bill extends the statute to cover all instances of
"pimping" an alien.
9
HOUSE OVERSIGHT 012380
20. Section 224
This section misunderstands the purpose and effect of the model law and should be
deleted. The Department's model law was never designed to supplant pre-existing state laws
which target pimping, pandering, or prostitution, but rather to supplement those laws. At the
time that the Department's model law was issued, most states had comprehensive laws
addressing prostitution, pimping, and pandering. However, most states did not have laws
focused on human trafficking. The Department's law was designed to raise awareness of the
issue of trafficking and to encourage states to closely examine cases to ensure that cases
involving fraud, force, and coercion are not labeled as prostitution offenses. The Department
believes the law has been successful in accomplishing this goal.
2L Section 231
The Department opposes any statutory changes to the annual report. The change in
subsection (1) is unnecessary as this language is currently included in the annual report. The
information requested in the new subsection (I) would be excessively burdensome to gather.
22. Section 232
DOJ opposes this addition as unnecessary. Human trafficking laws that do not require
the proof of force, fraud, or coercion, namely laws that concern minor victims of severe forms of
human trafficking, are already discussed at the annual conferences. To the extent that this
provision would require the Department to discuss human trafficking laws pertaining to adult
victims that do not require the showing of force, fraud, or coercion, such laws would not fail
under the definition of human trafficking and the annual conference would be an inappropriate
venue for the discussion of such laws. However, DOJ trafficking prosecutors utilize a wide
range of statutes in addition to Chapter 77 offenses to address all criminal conduct associated
with human trafficking. This includes the Mann Act, money laundering, visa fraud, immigration
offenses, criminal labor violations, and extortion, in addition to other criminal statutes.
Accordingly, DOJ training at annual conferences, the National Advocacy Center, the National
Center for Missing and Exploited Children, and field training with the Department of Justice
funded Human Trafficking Task Forces and provided through the Innocence Lost National
Initiative include discussion on the importance of using all available criminal statutes as essential
tools in charging decisions. Thus, this section is unnecessary.
23. Section 233
DOJ opposes the change to section 206 of the Trafficking Victims Protection
Reauthorization Act of 2005, which would remove the discretion of agencies in informing the
Senior Policy Operating Group (SPOG) of grants. Such a change could be read as giving the
SPOG oversight authority over grants. It also fails to take into consideration situations where
grant-making agencies may be unable to notify the SPOG of the grant.
10
HOUSE OVERSIGHT 012381
24. Section 234
The Department opposes subsection (a) as an excessively burdensome and unnecessary
creation of a new layer of bureaucracy within our agency. The Department does not believe
that there is currently any lack of coordination, and a new position could lead to duplication of
efforts. Furthermore, subsection (a)(2)(A) incorrectly lists the Civil Division and not the Civil
Rights Division.
25. Section 236
In subsection (a), DOJ questions the reliability of the congressional findings, especially
with respect to the estimated number of victims and the inference that the lack of child victims is
directly related to a lack of education individuals who may come into contact with human
trafficking victims. Such findings, without a full body of evidence, are counter-productive.
The Department also opposes subsection (b). The Attorney General should be involved
in any program that focuses on combating child trafficking at the border. We propose that
section (b)(1) is amended to read "The Secretary of Homeland Security, in conjunction with the
Secretary of State, Attorney General, and the Secretary of Health and Human Services." Further,
most of the children interdicted at the border are used for smuggling and are not trafficking
victims, In subsection (b)(5)(D), DOJ believes that the proceedings for removal to non-
contiguous countries are problematic because DHS needs more flexibility to handle gang
members, terrorists, repeat offenders, and state offenders. Furthermore, the terrorism exception
provided is too narrow to protect the national security interests of the country.
We oppose subsection (c)(1) to the extent that it limits the Administration's ability to
determine the best arrangement for custody or various classes of UACs. The administration will
work with DHS, DOJ, and MIS to refme and modify current detention practices where
necessary. The interagency process is the best forum to consider the various interests of
unaccompanied minors and law enforcement and to develop and adapt policies that, among other
things, provide for the safety of all concerned. We look forward to discussing these
developments with Congress in the future.
The Department opposes subsection (d)(2) as too narrowly construed. There are
numerous reasons, outside of the child proving to be a danger to himself or others, that require
children to be kept in a secure facility, including the safety of the child from danger that is not
self-imposed. In addition, the standard for placing minors in "secure" care is too strict. It
requires the "least restrictive setting that is in the best interest of the child." HE-IS only places 1.4
percent of minors in its care into a "secure" custody arrangement. This could mean that minors
who need this arrangement would instead be housed with children who have no history of
violence or criminal behavior. HHS needs more flexibility and there should not, therefore, be
required to make an "independent finding" of the child's danger to self or others.
DOJ opposes the language of subsection (d)(3Xc) that would afford HHS access to law
enforcement sensitive databases.
11
HOUSE OVERSIGHT 012382
The language of subsection (d)(5) must be changed from "shall ensure." This implies a
legal obligation on the Federal government to provide counsel and a concomitant right on behalf
of victims to government-funded counsel, which is inappropriate and would subject the
government to litigation over the nature and scope of the purported obligation and right.
The Department also opposes subsection (d)(6), which creates a guardian ad 'item
program. Such program raises serious conflict of interest concerns, and DOJ has opposed similar
language in the past. Establishment of a guardian ad [item program is also unnecessary in that 18
U.S.C. §3509(h) already sets forth detailed procedures which provide for court appointed
guardians ad litem for children who are victims of or witnesses to crimes involving abuse or
exploitation.
Subsection (d)(7) may result in unintended consequences due to this confidentiality
section. To effectively combat trafficking, relevant information must be transmitted to law
enforcement. Law enforcement is well-equipped to preserve confidentiality concerns,
The Department believes that subsection (e) undermines the 1997 Special Immigrant
Juvenile reforms and opposes turning this back over to the states, where it was inherently flawed.
In section 236(j), the effect of the apparent retroactivity of the general applicability of
these amendments to "all aliens in the United States before, on, or after the date of enactment of
this Act" raises serious concerns about the provision of benefits and services and has the
potential to create serious problems for the Department in its implementation of the programs
described in this section.
26. Section 301
DOJ recommends striking the 2 percent cap on funding for training and technical
assistance that is in 22 U.S.C. 7105(b)(2)(B). The unique.complexity of the trafficking issue and
the level of coordination necessary to effectively serve trafficking victims requires much more
training and technical assistance than a typical OP program. Striking the cap on training and
technical assistance will allow OJP to better allocate the trafficking funds it receives. The
change could be implemented by the following statutory language:
"Paragraph 107(b)(2)(B)of Pub. L. 106-386 is amended by:
"(I) inserting 'and' after the first semicolon;
"(2) striking '(ii)' through ';and'; and
"(3) striking 'OW and inserting `(ii)."
27. Section 302
Section 302 re-authorizes the $5,000,000 appropriation for the Pilot Program that was
first authorized by Section 203 of the 2005 version of this Act. The 2007 version, therefore,
should add language amending section 203 of the 2005 version to provide that HHS does not
have the exclusive authority for development of the pilot program. DOJ and DES must be
included in the development of this program to ensure that the ability of Federal prosecutors and
12
HOUSE OVERSIGHT 012383
law enforcement to gain access to these victims is not negatively impacted. Moreover, the
Departments' knowledge about these victims, their behaviors, and the dangers that are inherent
in providing shelter and services to them would be instrumental to ensuring the success of the
pilot program. This section should also amend subsection 203(a) of the 2005 reauthorization to
include after "Secretary of Health and Human Services", "in collaboration with the Attorney
General and the Secretary of Homeland Security," Subsection 203(c) should be likewise
amended.
The Office of Management and Budget has advised that there is no objection to the
presentation of this letter from the standpoint of the Administration's programs.
Sincerely,
4.2
Brian A. Benczkows
Principal Deputy Assistant Attorney General
cc: The Honorable Lamar S. Smith, Ranking Member, House Committee on the Judiciary
The Honorable Torn Lantos, Chairman, House Committee on Foreign Affairs
The Honorable Beam Ros-Lehtinen, Ranking Member, House Committee on Foreign
Affairs
The Honorable Patrick J. Leahy, Chairman, Senate Committee on the Judiciary
The Honorable Arlen Specter, Ranking Member, Senate Committee on the Judiciary
The Honorable Edward M. Kennedy, Chairman, Senate Committee on Health, Education,
Labor, and Pensions
The Honorable Michael B. Enzi, Ranking Member, Senate Committee on Health,
Education, Labor, and Pensions
The Honorable Joseph Biden, Chairman, Senate Committee on Foreign Relations
The Honorable Richard Lugar, Ranking Member, Senate Committee on Foreign
Relations
13
HOUSE OVERSIGHT 012384
TAB 12
HOUSE OVERSIGHT 012385
PRESIDENTIAL AUTHORITY TO DECLINE TO EXECUTE
UNCONSTITUTIONAL STATUTES
This memorandum discusses the President's constitutional authority to decline to execute
unconstitutional statutes.
November 2, 1994
MEMORANDUM FOR THE HONORABLE ABNER J. MIICVA
COUNSEL TO THE PRESIDENT
I have reflected further on the difficult questions surrounding a President's decision to decline to
execute statutory provisions that the President believes are unconstitutional, and I have a few thoughts
to share with you. Let me start with a general proposition that I believe to be uncontroversial: there are
circumstances in which the President may appropriately decline to enforce a statute that he views as
unconstitutional.
First, there is significant judicial approval of this proposition. Most notable is the Court's decision
in Myers v. United States, 272 U.S. 52 (1926). There the Court sustained the President's view that the
statute at issue was unconstitutional without any member of the Court suggesting that the President had
acted improperly in refusing to abide by the statute. More recently, in Freytag v. Commissioner, 501
U.S. 868 (1991), all four of the Justices who addressed the issue agreed that the President has "the
power to veto encroaching laws . . . or even to disregard them when they are unconstitutional." Id. at
906 (Scalia, J., concurring); see also Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 635-38
(1952) (Jackson, J., concurring) (recognizing existence of President's authority to act contrary to a
statutory command).
Second, consistent and substantial executive practice also confirms this general proposition.
Opinions dating to at least 1860 assert the President's authority to decline to effectuate enactments that
the President views as unconstitutional. See, e.g., Memorial of Captain Meigs, 9 Op. Att'y Gen. 462,
469-70 (1860) (asserting that the President need not enforce a statute purporting to appoint an officer);
see also annotations of attached Attorney General and Office of Legal Counsel opinions. Moreover, as
we discuss more fully below, numerous Presidents have provided advance notice of their intention not
to enforce specific statutory requirements that they have viewed as unconstitutional, and the Supreme
Court has implicitly endorsed this practice. See INS v. Chadha, 462 U.S. 919, 942 n.13 (1983) (noting
that Presidents often sign legislation containing constitutionally objectionable provisions and indicate
that they will not comply with those provisions).
While the general proposition that in some situations the President may decline to enforce
unconstitutional statutes is unassailable, it does not offer sufficient guidance as to the appropriate
course in specific circumstances. To continue our conversation about these complex issues, I offer the
following propositions for your consideration.
1. The President's office and authority are created and bounded by the Constitution; he is required to
act within its terms. Put somewhat differently, in serving as the executive created by the Constitution,
the President is required to act in accordance with the laws -- including the Constitution, which takes
precedence over other forms of law. This obligation is reflected in the Take Care Clause and in the
President's oath of office.
2. When bills are under consideration by Congress, the executive branch should promptly identify
unconstitutional provisions and communicate its concerns to Congress so that the provisions can be
corrected. Although this may seem elementary, in practice there have been occasions in which the
President has been presented with enrolled bills containing constitutional flaws that should have been
HOUSE OVERSIGHT 012386
corrected in the legislative process.
3. The President should presume that enactments are constitutional. There will be some occasions,
however, when a statute appears to conflict with the Constitution. In such cases, the President can and
should exercise his independent judgment to determine whether the statute is constitutional. In
reaching a conclusion, the President should give great deference to the fact that Congress passed the
statute and that Congress believed it was upholding its obligation to enact constitutional legislation.
Where possible, the President should construe provisions to avoid constitutional problems.
4. The Supreme Court plays a special role in resolving disputes about the constitutionality of
enactments. As a general matter, if the President believes that the Court would sustain a particular
provision as constitutional, the President should execute the statute, notwithstanding his own beliefs
about the constitutional issue. If, however, the President, exercising his independent judgment,
determines both that a provision would violate the Constitution and that it is probable that the Court
would agree with him, the President has the authority to decline to execute the statute.
5. Where the President's independent constitutional judgment and his determination of the Court's
probable decision converge on a conclusion of unconstitutionality, the President must make a decision
about whether or not to comply with the provision. That decision is necessarily specific to context, and
it should be reached after careful weighing of the effect of compliance with the provision on the
constitutional rights of affected individuals and on the executive branch's constitutional authority. Also
relevant is the likelihood that compliance or non-compliance will permit judicial resolution of the
issue. That is, the President may base his decision to comply (or decline to comply) in part on a desire
to afford the Supreme Court an opportunity to review the constitutional judgment of the legislative
branch.
6. The President has enhanced responsibility to resist unconstitutional provisions that encroach upon
the constitutional powers of the Presidency. Where the President believes that an enactment
unconstitutionally limits his powers, he has the authority to defend his office and decline to abide by it,
unless he is convinced that the Court would disagree with his assessment. If the President does not
challenge such provisions (i.e., by refusing to execute them), there often will be no occasion for
judicial consideration of their constitutionality; a policy of consistent Presidential enforcement of
statutes limiting his power thus would deny the Supreme Court the opportunity to review the
limitations and thereby would allow for unconstitutional restrictions on the President's authority.
Some legislative encroachments on executive authority, however, will not be justiciable or are for
other reasons unlikely to be resolved in court. If resolution in the courts is unlikely and the President
cannot look to a judicial determination, he must shoulder the responsibility of protecting the
constitutional role of the presidency. This is usually true, for example, of provisions limiting the
President's authority as Commander in Chief. Where it is not possible to construe such provisions
constitutionally, the President has the authority to act on his understanding of the Constitution.
One example of a Presidential challenge to a statute encroaching upon his powers that did result in
litigation was Myers v. United States, 272 U.S. 52 (1926). In that case, President Wilson had defied a
statute that prevented him from removing postmasters without Senate approval; the Supreme Court
ultimately struck down the statute as an unconstitutional limitation on the President's removal power.
Myers is particularly instructive because, at the time President Wilson acted, there was no Supreme
Court precedent on point and the statute was not manifestly unconstitutional. In fact, the
constitutionality of restrictions on the President's authority to remove executive branch officials had
been debated since the passage of the Tenure of Office Act in 1867 over President Johnson's veto. The
closeness of the question was underscored by the fact that three Justices, including Justices Holmes and
Brandeis, dissented in Myers. Yet, despite the unsettled constitutionality of President Wilson's action,
no member of the Court in Myers suggested that Wilson overstepped his constitutional authority -- or
HOUSE OVERSIGHT 012387
even acted improperly -- by refusing to comply with a statute he believed was unconstitutional. The
Court in Myers can be seen to have implicitly vindicated the view that the President may refuse to
comply with a statute that limits his constitutional powers if he believes it is unconstitutional. As
Attorney General Civiletti stated in a 1980 opinion,
Myers is very nearly decisive of the issue [of Presidential denial of the validity of statutes].
Myers holds that the President's constitutional duty does not require him to execute
unconstitutional statutes; nor does it require him to execute them provisionally, against the
day that they are declared unconstitutional by the courts. He cannot be required by statute
to retain postmasters against his will unless and until a court says that he may lawfully let
them go. If the statute is unconstitutional, it is unconstitutional from the start.
The Attorney General's Duty to Defend and Enforce Constitutionally Objectionable Legislation, 4A
Op. O.L.C. 55, 59 (1980).
7. The fact that a sitting President signed the statute in question does not change this analysis. The
text of the Constitution offers no basis for distinguishing bills based on who signed them; there is no
constitutional analogue to the principles of waiver and estoppel. Moreover, every President since
Eisenhower has issued signing statements in which he stated that he would refuse to execute
unconstitutional provisions. See annotations of attached signing statements. As we noted in our
memorandum on Presidential signing statements, the President "may properly announce to Congress
and to the public that he will not enforce a provision of an enactment he is signing. If so, then a signing
statement that challenges what the President determines to be an unconstitutional encroachment on his
power, or that announces the President's unwillingness to enforce (or willingness to litigate) such a
provision, can be a valid and reasonable exercise of Presidential authority." Memorandum for Bernard
N. Nussbaum, Counsel to the President, from Walter Dellinger, Assistant Attorney General, Office of
Legal Counsel at 4 (Nov. 3, 1993). (Of course, the President is not obligated to announce his
reservations in a signing statement; he can convey his views in the time, manner, and form of his
choosing.) Finally, the Supreme Court recognized this practice in INS v. Chadha, 462 U.S. 919 (1983):
the Court stated that "it is not uncommon for Presidents to approve legislation containing parts which
are objectionable on constitutional grounds" and then cited the example of President Franklin
Roosevelt's memorandum to Attorney General Jackson, in which he indicated his intention not to
implement an unconstitutional provision in a statute that he had just signed. Id. at 942 n.13. These
sources suggest that the President's signing of a bill does not affect his authority to decline to enforce
constitutionally objectionable provisions thereof.
• In accordance with these propositions, we do not believe that a President is limited to choosing
between vetoing, for example, the Defense Appropriations Act and executing an unconstitutional
provision in it. In our view, the President has the authority to sign legislation containing desirable
elements while refusing to execute a constitutionally defective provision.
We recognize that these issues are difficult ones. When the President's obligation to act in accord
with the Constitution appears to be in tension with his duty to execute laws enacted by Congress,
questions are raised that go to the heart of our constitutional structure. In these circumstances, a
President should proceed with caution and with respect for the obligation that each of the branches
shares for the maintenance of constitutional government.
Walter Dellinger
Assistant Attorney General
Brief Description of Attached Materials
HOUSE OVERSIGHT 012388
Attorney General Opinions
1) Memorial of Captain Meigs, 9 Op. Atry Gen. 462 (1860): In this opinion the Attorney General
concluded that the President is permitted to disregard an unconstitutional statute. Specifically, Attorney
General Black concluded that a statute purporting to appoint an officer should not be enforced: "Every
law is to be carried out so far forth as is consistent with the Constitution, and no further. The sound part
of it must be executed, and the vicious portion of it suffered to drop." Id. at 469.
2) Constitutionality of Congress' Disapproval of Agency Regulations by Resolutions Not Presented to
the President, 4A Op. O.L.C. 21 (1980): In this opinion Attorney General Civiletti instructed Secretary
of Education Hufstedler that she was authorized to implement regulations that had been disapproved by
concurrent congressional resolutions, pursuant to a statutory legislative veto. The Attorney General•
noted that "the Attorney General must scrutinize with caution any claim that he or any other executive
officer may decline to defend or enforce a statute whose constitutionality is merely in doubt." Id. at 29.
He concluded, however, that "[t]o regard these concurrent resolutions as legally binding would impair
the Executive's constitutional role and might well foreclose effective judicial challenge to their
constitutionality. More important, I believe that your recognition of these concurrent resolutions as
legally binding would constitute an abdication of the responsibility of the executive branch, as an equal
and coordinate branch of government with the legislative branch, to preserve the integrity of its
functions against constitutional encroachment." Id.
3) The Attorney General's Duty to Defend and Enforce Constitutionally Objectionable Legislation, 4A
Op. O.L.C. 55 (1980): Attorney General Civiletti, in answer to a congressional inquiry, observed that
"Myers holds that the President's constitutional duty does not require him to execute unconstitutional
statutes; nor does it require him to execute them provisionally, against the day that they are declared
unconstitutional by the courts." Id. at 59. He added as a cautionary note that "[t]he President has no
'dispensing power," meaning that the President and his subordinates "may not lawfully defy an Act of
Congress if the Act is constitutional. . . . In those rare instances in which the Executive may lawfully
act in contravention of a statute, it is the Constitution that dispenses with the operation of the statute.
The Executive cannot." Id. at 59-60.
4) Letter from William French Smith, Attorney General, to Peter W. Rodino, Jr., Chairman, House
Judiciary Committee (Feb. 22 1985): This letter discussed the legal precedent and authority for the
President's refusal to execute a provision of the Competition in Contracting Act. The Attorney General
noted that the decision "not to implement the disputed provisions has the beneficial byproduct of
increasing the likelihood of a prompt judicial resolution. Thus, far from unilaterally nullifying an Act
of Congress, the Department's actions are fully consistent with the allocation of judicial power by the
Constitution to the courts." Id. at 8. The letter also stated that "the President's failure to veto a measure
does not prevent him subsequently from challenging the Act in court, nor does presidential approval of
an enactment cure constitutional defects." Id. at 3.
Office of Legal Counsel Opinions
1) Memorandum to the Honorable Robert J. Lipshutz, Counsel to the President, from John M.
Harmon, Assistant Attorney General, Office of Legal Counsel (Sept. 27, 1977): This opinion
concluded that the President may lawfully disregard a statute that he interprets to be unconstitutional.
We asserted that "cases may arise in which the unconstitutionality of the relevant statute will be
certain, and in such a case the Executive could decline to enforce the statute for that reason alone." Id.
at 13. We continued, stating that "[u]nless the unconstitutionality of a statute is clear, the President
should attempt to resolve his doubts in a way that favors the statute, and he should not decline to
enforce it unless he concludes that he is compelled to do so under the circumstances." Id. We declined
to catalogue all the considerations that would weigh in favor of non-enforcement, but we identified
two: first the extent of the harm to individuals or the government resulting from enforcement; and,
HOUSE OVERSIGHT 012389
second, the creation of an opportunity for a court challenge through non-enforcement (e.g., Myers).
2) Appropriations Limitation for Rules Vetoed by Congress, 4B Op. 0.L.C. 731 (1980): In this
opinion we rejected the constitutionality of a proposed legislative veto, prior to the Court's decision in
Chadha. We opined that "[t]o regard this provision as legally binding would impair the Executive's
constitutional role and would constitute an abdication of the responsibility of the Executive Branch."
Id. at 734. It should be noted that the legislation in question was pending in Congress, and the
possibility that President Carter would sign the legislation did not affect our analysis of the
constitutional issue. We simply stated that, "if enacted, the [legislative veto provision] will not have
any legal effect." Id.
3) Issues Raised by Section 102(c)(2) of H.R. 3792, 14 Op. O.L.C. 38 (1990) (preliminary print): This
opinion also addressed then-pending legislation, in this case the foreign relations authorization bill for
fiscal years 1990 and 1991. The opinion found that a provision of the bill was unconstitutional and
severable. Regarding non-execution, the opinion stated that "at least in the context of legislation that
infringes the separation of powers, the President has the constitutional authority to refuse to enforce
unconstitutional laws." Id. at 53. The opinion concluded that "if the President chooses to sign H.R.
3792, he would be constitutionally authorized to decline to enforce" the constitutionally objectionable
section. Id. at 38.
4) Issues Raised by Section 129 of Pub. L. No. 102-138 and Section 503 of Pub. L. No. 102-140, 16
Op. O.L.C. 18 (1992) (preliminary print): This opinion concluded that two statutory provisions that
limited the issuance of official and diplomatic passports were unconstitutional and were severable from
the remainder of the two statutes. On the question of non-execution, the opinion rejected "the argument
that the President may not treat a statute as invalid prior to a judicial determination." Id. at 40. The
opinion concluded that the Constitution authorizes the President to refuse to enforce a law that he
believes is unconstitutional.
5) Memorandum for Bernard N. Nussbaum, Counsel to the President, from Walter Dellinger, Assistant
Attorney General, Office of Legal Counsel (Nov. 3, 1993): This opinion discusses different categories
of signing statements, including those construing bills to avoid constitutional problems and those in
which the President declares "that a provision of the bill before him is flatly unconstitutional, and that
he will refuse to enforce it." Id. at 3. The opinion concludes that such "uses of Presidential signing
statements generally serve legitimate and defensible purposes." Id. at 7.
Presidential Signing Statements
1) Statement by the State Department (Announcing President Wilson's Refusal to Carry Out the
Section of the Jones Merchant Marine Act of June 5, 1920, directing him to terminate treaty provisions
restricting the Government's right to impose discriminatory tonnage dues and tariff duties), 17 A
Compilation of the Messages and Papers of the Presidents 8871 (Sept. 24, 1920) (Pres. Wilson): The
State Department announced that it "has been informed by the President that he does not deem the
direction contained in Section 34 of the so-called Merchant Marine Act an exercise of any
constitutional power possessed by the Congress." Id. The statement also defended President Wilson's
decision to sign the bill and noted that "the fact that one section of the law involves elements of
illegality rendering the section inoperative need not affect the validity and operation of the Act as a
whole." 5 Green Haywood Hackworth, Digest of International Law 324 (1943).
2) Special Message to the Congress Upon Signing the Department of Defense Appropriation Act, Pub.
Papers of Dwight D. Eisenhower 688 (July 13, 1955): President Eisenhower, in signing a bill (H.R.
6042) that contained a legislative veto, stated that the legislative veto "will be regarded as invalid by
the executive branch of the Government in the administration of H.R. 6042, unless otherwise
determined by a court of competent jurisdiction." Id. at 689. -
HOUSE OVERSIGHT 012390
3) Memorandum on Informing Congressional Committees of Changes Involving Foreign Economic
Assistance Funds, Pub. Papers of John F. Kennedy 6 (Jan. 9, 1963): President Kennedy stated that a
provision in the bill he was signing contained an unconstitutional legislative veto. He announced that
"[i]t is therefore my intention . . . to treat this provision as a request for information." Id.
4) Statement by the President Upon Approving the Public Works Appropriations Act, Pub. Papers of
Lyndon B. Johnson 104 (Dec. 31, 1963): President Johnson also found that a legislative veto provision
was unconstitutional and stated that he would treat it as a request for information.
5) Statement About Signing the Public Buildings Amendments of 1972, Pub. Papers of Richard Nixon
686 (June 17, 1972): President Nixon stated that a clause conditioning the use of authority by the
executive branch on the approval of a congressional committee was unconstitutional. He ordered the
agency involved to comply with "the acceptable procedures" in the bill "without regard to the
unconstitutional provisions I have previously referred to." Id. at 687.
6) Statement on Signing the Department of Defense Appropriation Act of 1976, Pub. Papers of Gerald
R. Ford 241 (Feb. 10, 1976): President Ford stated that a committee approval mechanism was
unconstitutional and announced that he would "treat the unconstitutional provision . . . to the extent it
requires further Congressional committee approval, as a complete nullity." Id. at 242.
7) Statement on Signing Coastal Zone Management Improvement Act of 1980, Pub. Papers of Jimmy
Carter 2335 (Oct. 18, 1980): President Carter stated that a legislative veto provision was
unconstitutional and that any attempt at a legislative veto would "not [be] regarded as legally binding."
Id.
8) Statement on Signing the Union Station Redevelopment Act of 1981, Pub. Papers of Ronald
Reagan 1207 (Dec. 29, 1981): President Reagan stated that a legislative veto was unconstitutional and
announced that "[t]he Secretary of Transportation will not . . . regard himself as legally bound by any
such resolution." Id.
9) Statement On Signing the National and Community Service Act of 1990, Pub. Papers of George
Bush 1613 (Nov. 16, 1990): President Bush rejected the constitutionality of provisions that required a
Presidentially appointed board exercising executive authority to include, among its 21 members,
"seven members nominated by the Speaker of the House of Representatives . .. [and] seven members
nominated by the Majority Leader of the Senate." Id. at 1614. He announced that the restrictions on his
choice of nominees to the board "are without legal force or effect." Id.
10) 7 A Compilation of the Messages and Papers of the Presidents 377 (Aug. 14, 1876) (Pres. Grant):
This is one of the earliest of many instances of a President "construing" a provision (to avoid
constitutional problems) in a way that seems to amount to a refusal to enforce a provision of it. An
1876 statute directed that notices be sent to certain diplomatic and consular officers "to close their
offices." President Grant, in signing the bill, stated that, "[i]n the literal sense of this direction it would
be an invasion of the constitutional prerogatives and duty of the Executive." Id. In order to avoid this
problem, President Grant "constru[edr this provision "only to exercise the constitutional prerogative of
Congress over the expenditures of the Government," not to "imply[] a right in the legislative branch to
direct the closing or discontinuing of any of the diplomatic or consular offices of the Government." Id.
at 378.
Other Presidential Documents
1) A Presidential Legal Opinion, 66 Harv. L. Rev. 1353 (1953): This was a legal opinion from
President Franklin Roosevelt to Attorney General Jackson. President Roosevelt stated that he was
signing the Lend-Lease Act despite a provision providing for a legislative veto, "a provision which, in
HOUSE OVERSIGHT 012391
my opinion, is clearly unconstitutional." Id. at 1357. The President stated that, "[i]n order that I may be
on record as indicating my opinion that the foregoing provision of the so-called Lend-Lease Act is
unconstitutional, and in order that my approval of the bill, due to the existing exigencies of the world
situation, may not be construed as a tacit acquiescence in any contrary view, I am requesting you to
place this memorandum in the official files of the Department of Justice. I am desirous of having this
done for the further reason that I should not wish my action in approving the bill which includes this
invalid clause, to be used as a precedent for any future legislation comprising provisions of a similar
nature." Id. at 1358.
2) Message to the Congress on Legislative Vetoes, Pub. Papers of Jimmy Carter 1146 (Jun. 21, 1978):
In this memorandum President Carter expressed his strong opposition to legislative vetoes and stated
that "[t]he inclusion of [a legislative veto] in a bill will be an important factor in my decision to sign or
to veto it." Id. at 1148. He further stated that, "[a]s for legislative vetoes over the execution of programs
already prescribed in legislation and in bills I must sign for other reasons, the Executive Branch will
generally treat them as 'report-and-wait' provisions. In such a case, if Congress subsequently adopts a
resolution to veto an Executive action, we will give it serious consideration, but we will not, under our
reading of the Constitution, consider it legally binding." Id. at 1149.
Historical Materials
1) Statement of James Wilson on December 1, 1787 on the Adoption of the Federal Constitution,
reprinted in 2 Jonathan Elliot, Debates on the Federal Constitution 418 (1836): Wilson argued that the
Constitution imposed significant -- and sufficient -- restraints on the power of the legislature, and that
the President would not be dependent upon the legislature. In this context, he stated that "the power of
the Constitution was paramount to the power of the legislature acting under that Constitution; for it is
possible that the legislature . . . may transgress the bounds assigned to it, and an act may pass, in the
usual mode notwithstanding that transgression; but when it comes to be discussed before the judges,--
when they consider its principles, and find it to be incompatible with the superior power of the
Constitution,-- it is their duty to pronounce it void . . . . In the same manner, the President of the United
States could shield himself, and refuse to carry into effect an act that violates the Constitution." Id. at
445-46.
2) Letter from Chief Justice Chase to Gerrit Smith (Apr. 19, 1868), quoted in J. Schuckers, The Life
and Public Services of Salmon Portland Chase 577 (1874): Chase stated that President Johnson took
the proper action in removing Secretary of War Stanton without Senate approval, in light of Johnson's
belief that the statutory restriction on his removal authority was unconstitutional. In this regard, Chase
commented that "the President had a perfect right, and indeed was under the highest obligation, to
remove Mr. Stanton, if he made the removal not in wanton disregard of a constitutional law, but with a
sincere belief that the Tenure-of-Office Act was unconstitutional and for the purpose of bringing the
question before the Supreme Court." Id. at 578.
Congressional Materials
1) The President's Suspension of the Competition in Contracting Act is Unconstitutional, H.R. Rep.
No. 138, 99th Cong., 1st Sess. (1985): The House Committee on Government Operations concluded
that the President lacked the authority to refuse to implement any provision of the Competition in
Contracting Act. The Committee stated that, "fflo adopt the view that one's oath to support and defend
the Constitution is a license to exercise any available power in furtherance of one's own constitutional
interpretation would quickly destroy the entire constitutional scheme. Such a view, whereby the
President pledges allegiance to the Constitution but then determines what the Constitution means,
inexorably leads to the usurpation by the Executive of the others' roles." Id. at 11. The Committee also
stated that "[t]he Executive's suspension of the law circumvents the constitutionally specified means
for expressing Executive objections to law and is a constitutionally impermissible absolute veto
HOUSE OVERSIGHT 012392
power." Id. at 13.
2) Memorandum from the Congressional Research Service to the Committee on Government
Operations concerning "The Executive's Duty to Enforce the Laws" (Feb. 6, 1985), reprinted in
Constitutionality of GAO's Bid Protest Function: Hearings Before a Subcomm. of the House Comm.
on Government Operations, 99th Cong., 1st Sess. 544 (1985): This memorandum stated that the
President lacks the authority to decline to enforce statutes. The CRS argued that "[t]he refusal of the
President to execute the law is indistinguishable from the power to suspend the laws. That power, as is
true of the power to amend or to revive an expired law, is a legislative power." Id. at 554.
Cases (not included in the submitted materials)
1) Myers v. United States, 272 U.S. 52 (1926): The President refused to comply with -- that is, enforce
-- a limitation on his power of removal that he regarded as unconstitutional, even though the question
had not been addressed by the Supreme Court. A member of Congress, Senator Pepper, urged the
Supreme Court to uphold the validity of the provision. The Supreme Court vindicated the President's
interpretation without any member of the Court indicating that the President had acted unlawfully or
inappropriately in refusing to enforce the removal restriction based on his belief that it was
unconstitutional.
2) United States v. Lovett, 328 U.S. 303 (1946): The President enforced a statute that directed him to
withhold compensation from three named employees, even though the President believed the law to be
unconstitutional. The Justice Department argued against the constitutionality of the statute in the
ensuing litigation. (The Court permitted an attorney to appear on behalf of Congress, amicus curiae, to
defend the statute.)
3) INS v. Chadha, 462 U.S. 919 (1983): This case involved the withholding of citizenship from an
applicant pursuant to a legislative veto of an Attorney General decision to grant citizenship. Despite a
Carter Administration policy against complying with legislative vetoes (see Carter Presidential
memorandum, supra), the executive branch enforced the legislative veto, and, in so doing, allowed for
judicial review of the statute. As with Lovett, the Justice Department argued against the
constitutionality of the statute.
4) Morrison v. Olson, 487 U.S. 654 (1988): The President viewed the independent counsel statute as
unconstitutional. The Attorney General enforced it, making findings and forwarding them to the
Special Division. In litigation, however, the Justice Department attacked the constitutionality of the
statute and left its defense to the Senate Counsel, as amicus curiae, and the independent counsel
herself.
5) Freytag v. Commissioner, 501 U.S. 868 (1991): A unanimous Court ruled that the appointment of
special trial judges by the Chief Judge of the United States Tax Court did not violate the Appointments
Clause. Five Justices concluded that the Tax Court was a "Court of Law" for Appointments Clause
purposes, despite the fact that it was an Article I court, so that the Tax Court could constitutionally
appoint inferior officers. Four Justices, in a concurrence by Justice Scalia, contended that the Tax Court
was a "Department" under the Appointments Clause. The concurrence stated that "Court of Law" did
not include Article I courts and that the Framers intended to prevent Congress from having the power
both to create offices and to appoint officers. In this regard, the concurrence stated that "it was not
enough simply to repose the power to execute the laws (or to appoint) in the President; it was also
necessary to provide him with the means to resist legislative encroachment upon that power. The
means selected were various, including a separate political constituency, to which he alone was
responsible, and the power to veto encroaching laws, see Art. I, § 7, or even to disregard them when
they are unconstitutional." Id. at 906 (Scalia, J., concurring).
HOUSE OVERSIGHT 012393
6) Lear Siegler, Inc., Energy Products Division v. Lehman, 842 F.2d 1102 (9th Cir. 1988), withdrawn
in part 893 F.2d 205 (9th Cir. 1990) (en banc): The President refused to comply with provisions of the
Competition in Contracting Act that he viewed as unconstitutional and thereby allowed for judicial
resolution of the issue. The Ninth Circuit rejected the President's arguments about the constitutionality
of the provisions. The court further determined that Lear Siegler was a prevailing party and was
entitled to attorneys' fees, because the executive branch acted in bad faith in refusing to execute the
contested provisions. In this regard, the court stated that the President's action was "utterly at odds with
the texture and plain language of the Constitution," because a statute is part of the law of the land that
the President is obligated to execute. Id. at 1121, 1124. On rehearing en banc, the court ruled that Lear
Siegler was not a prevailing party and withdrew the sections of the opinion quoted above.
HOUSE OVERSIGHT 012394
TAB 13
HOUSE OVERSIGHT 012395
-0929104.TXT
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2006 CF09454AXX
STATE OF FLORIDA,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
Wednesday, February 20, 2008
2:00 p.m. - 4:30 p.m.
Palm Beach County Courthouse
205 North Dixie Highway
West Palm Beach, Florida 33401
Reported By:
Judith F. Consor, FPR
Notary Public, State of Florida
Consor & Associates Reporting and Transcription
Phone - 561.682.0905
1 APPEARANCES:
2 On behalf of the State:
3 LANNA BELOHLAVEK, ESQ.
ASSISTANT STATE ATTORNEY
4 401 North Dixie Highway
West Palm Beach, Florida 33401
5 561.355.7100
6 On behalf of the Defendant:
7 MICHAEL R. TEIN, ESQ.
KATHRYN A. MEYERS, ESQ.
8 LEWIS TEIN, PL
3059 GRAND AVENUE, SUITE 340
Page 1
2
HOUSE OVERSIGHT 012396
-0929104.TXT
9   COCONUT GROVE, FL 33133
10
On behalf of the Defendant:
11   JACK A. GOLDBERGER, ESQ.
ATTERBURY, GOLDBERGER & WEISS
12   250 AUSTRALIAN AVENUE SOUTH
SUITE 1400
13   WEST PALM BEACH, FLORIDA 33401
561.659.8300
14
15   ALSO PRESENT:
16   KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE
17
18
19
20
21
22
23
24
25
3
1   INDEX
2   WITNESS:   PAGE:
3
DIRECT EXAMINATION   4
4   BY MR. TEIN:
5
6   - - -
7   NO EXHIBITS MARKED
8   - - -
9
10
11
12
13
Page 2
HOUSE OVERSIGHT 012397
-0929104.TXT
14
15
16
17
18
19
20
21
22
23
24
25
4
1
2
3
4
5 Thereupon,
6
7
8
9
10
11 BY MR. TEIN:
12
13 name.
14 A.
15
16 A.
17
Deposition taken before Judith F. Consor,
Court Reporter and Notary Public in and for the State of
Florida at Large, in the above cause.
having been first duly sworn or affirmed, was examined
and testified as follows:
THE WITNESS: I do.
DIRECT EXAMINATION
Q. Good afternoon. Please tell me your full
Q. And can you please spell it?
Page 3
HOUSE OVERSIGHT 012398
-0929104.TXT
18 Q. Thank you.
19 May I call you
20 A. Uh-huh.
21 Q. , I'm going to ask you a few
22 questions, several questions today. If at any time you
23 want to take a break, you just let me know. Okay?
24 A. Okay.
25 Q. If you at any time don't understand one of
5
1 my questions, will you just please let me know?
2 A. Yes
3 Q. And if at any time you're not feeling well
4 or something like that, you'll tell us, right?
5 A. Yes.
6 Q. Do you feel okay today?
7 A. Yes.
8 Q. Not taking any alcohol or drugs or anything
9 like that, right?
10 A. No.
11 Q. So you feel ready to have your deposition
12 taken?
13 A. Yes.
14 Q. 111111 what is your address?
15 A. I'm currently living at my aunt's house and
16 I don't know it off the top of my head.
17 Q. Where is it?
18 A. In Jupiter.
19 Q. Who is your aunt?
20 A.
21 Q. Who else is living there?
22 A. my uncle.
Page 4
HOUSE OVERSIGHT 012399
-0929104.TXT
23 Q. Anyone else living there?
24 A. No.
25 Q. The contempt motion that your mother filed
6
1 against your father regarding your fifty million-dollar
2 lawsuit against Jeffrey Epstein says that you live with
3 your aunt and uncle and have been living there; is that
4 correct?
5 A. Yes.
6 Q. How long have you been living with your
7 aunt and uncle?
8 A. Since my father kicked me out.
9 Q. That was Thanksgiving of this past year?
10 A. Yes, sir.
11 Q. Okay. Didn't did your firefighter boy
12 friend _____________________ get an apartment for the two of
13 you?
14 A. No, sir. He has an apartment, but by
15 himself.
16 Q. Did he get an apartment for the two of you
17 to live in?
18 A. No, sir.
19 Q. Are you planning to move in with him?
20 A. Maybe one day in the future
21 O. Do you have a plan to move in with him
22 presently?
23 A. No.
24 Q. Have you been to the apartment that you and
25 have discussed moving in together?
Page 5
HOUSE OVERSIGHT 012400
-0929104.TXT
7
1 A. I have been to the apartment.
2 Q. Where is that?
3 A.
4 Q. Have you spent the night over there?
5 A. No, sir.
6 Q. Do you know the address there?
7 A. I do not.
8 Q. Isn't your sister planning on living
9 with you and 1111.
10 A. No.
11 Q. you know that this court case is a
12 criminal prosecution, correct?
13 A. Correct.
14 Q. And you know that it's a criminal
15 prosecution against a man who has no criminal background.
16 Do you know that?
17 A. I do now.
18 Q. You agree that court is a very serious
19 matter?
20 A. Yes.
21 Q. And you're here with your lawyer
22 Mr. Leopold, right?
23 A. Yes.
24 Q. And you know that Mr. Leopold recently
25 filed a lawsuit in federal court against Jeffrey Epstein,
8
1 seeking fifty million dollars.
2 MR. LEOPOLD: Let me just object.
3 let me instruct you. Anything that
4 you have learned through conversations between you
Page 6
HOUSE OVERSIGHT 012401
-0929104.TXT
5 and me are protected. So if you know any of that
6 information outside of those discussions, you may
7 answer. But if the only way you know it is
8 through our discussions, do not answer that
9 question.
10 BY MR. TEIN:
11 Q. you know that Mr. Leopold recently
12 filed a lawsuit in federal court on your behalf against
13 Jeffrey Epstein seeking fifty million dollars.
14 MR. LEOPOLD: Same objection.
15 If you know the answer to that outside of
16 our discussions, you may answer. If it is the
17 only way that you know the answer is through our
18 discussions, do not answer that question.
19 THE WITNESS: Okay.
20 MR. LEOPOLD: Attorney/client privilege.
21 BY MR. TEIN:
22 Q. You can answer the question unless
23 MR. LEOPOLD: Same objection.
24 MR. TEIN: Let me finish.
25 MR. LEOPOLD: Excuse me. We're
9
1 MR. TEIN: No. Let me finish.
2 MR. LEOPOLD: Lewis, we're not going to do
3 that.
4 MR. TEIN: My name is not Lewis.
5 I'm going to finish my question. Okay?
6 MR. LEOPOLD: Do not answer until you hear
7 from me.
8 BY MR. TEIN:
Page 7
HOUSE OVERSIGHT 012402
-0929104.TXT
9 Q. Other than conversations that you have had
10 with Mr. Leopold -- I'm not asking about that -- are you
11 aware that Mr. Leopold has filed a lawsuit in federal
12 court seeking fifty million dollars from Jeffrey Epstein
13 on your behalf?
14 MR. LEOPOLD: Same objection.
15 Anything that you learn through
16 conversations between you and me, do not answer.
17 Those are protected. If you know through any
18 other realm of knowledge, you may answer.
19 THE WITNESS: No.
20 BY MR. TEIN:
21 Q. You have no idea that Mr. Leopold filed a
22 fifty million-dollar lawsuit on your behalf against
23 Jeffrey Epstein?
24 MR. LEOPOLD: Same objection.
25 Do not answer that question if it's through
10
1 discussions that you and I had. Outside of that,
2 you may answer. So do not answer that question if
3 that is the only basis by which you understand
4 that answer.
5 THE WITNESS: No.
6 BY MR. TEIN:
7 Q. You didn't know that?
8 MR. LEOPOLD: Don't answer that question.
9 Against, it's attorney/client privilege. Any
10 information you've learned through conversations
11 between you and I are protected. If you know it
12 through any other realm, you may answer.
13 MR. TEIN: Are you going to say that for
Page 8
HOUSE OVERSIGHT 012403
-0929104.TXT
14 every question in the deposition, Mr. Leopold?
15 MR. LEOPOLD: When you ask improper
16 questions like that without the proper --
17 MR. TEIN: You're going to stop your
18 speaking objections right now. Okay?
19 MR. LEOPOLD: Without the proper --
20 MR. TEIN: You need to stop your speaking
21 objections.
22 Let's continue.
23 MR. LEOPOLD: Counsel, you just asked me a
24 question and I'm going to state it on the
25 record --
11
1 MR. TEIN: You need to stop your speaking
2 objections. Check your rules.
3 MR. LEOPOLD: Excuse me. For the record,
4 Counsel asked me a question. I'll state the
5 answer on the record. He asked me the question am
6 I going to be answering that way throughout the
7 deposition. So long as there's improper
8 foundation and predicate asked by the attorney, I
9 will protect my client and I make the record where
10 appropriate. If counsel wishes to ask an
11 appropriate worded question with the proper
12 foundation and predicate, I will certainly allow
13 the client to answer the question.
14 MR. GOLDBERGER: Why don't you just state
15 attorney/client privilege and just be done with
16 it.
17 MR. LEOPOLD: I want the record to be
Page 9
HOUSE OVERSIGHT 012404
-0929104.TXT
18 clear.
19 MR. TEIN: You want to waste time is what
20 you want to do. You were supposed to be here this
21 morning and you totally broke the deal, the
22 agreement that you had with us if your hearing got
23 cancelled.
24 But let's move on and maybe you'll stop
25 obstructing this deposition.
12
1 MR. LEOPOLD: I think the record is very
2 clear where we stand thus far.
3 Is there a recording taken of this
4 deposition?
5 THE COURT REPORTER: Yes.
6 MR. LEOPOLD: Just make sure that's
7 preserved.
8 BY MR. TEIN:
9 Q. Go to Exhibit 20-01 -- well, before you do
10 that, , are you aware that a lawyer named Jeffrey
11 Herman filed a lawsuit on your behalf, yes or no?
12 MR. LEOPOLD: Objection.
13 Any conversations that you and I have had
14 regarding that, if that is the only way by which
15 you understand how to answer that question, so not
16 answer. It's attorney/client privilege, as well
17 as any conversations you may have had with the
18 attorney from Miami. That is also attorney/client
19 privilege. And I'm assuming --
20 MR. TEIN: You're actually wrong about the
21 attorney/client privilege.
22 MR. LEOPOLD: I'm assuming Counsel is not
Page 10
HOUSE OVERSIGHT 012405
-0929104.TXT
23 asking you to divulge attorney/client --
24 MR. TEIN: Of course not.
25 BY MR. TEIN:
13
1
2'
4 tAU4IfEagAblaglaft0SORMODWYAK0000
4 MR. LEOPOLD: Same objection.
5 MR. TEIN: We've heard the objection 10
6 times already.
7 MR. LEOPOLD: Counsel, excuse me.
8 MR. TEIN: Just say attorney/client
9 privilege. Stop interrupting my questions.
10 MR. LEOPOLD: I'm entitled to make an
11 objection for the record, which I'm doing, and
12 I'll make the same objection. And if it calls for
13 attorney/client privilege, any conversations you
14 and I have had, do not answer the question.
15 And I think that it might be appropriate
16 for the record to ask questions via
17 as opposed to I think that would be more
18 appropriate for this deposition.
19 BY MR TEIN:
20 Q. Go ahead. Please answer yes or no.
21 la TOD
22 Q. Thank you.
23 In fact, you know that Mr. Herman held a
24 press conference after he filed the fifty-million-dollar
25 lawsuit on your behalf, don't you?
Q. 400iiii.P.0:41.5-0MOVA.Offriqw.liAtm4Rg
biVAttotoOgeft toutigfiftS00 tITWOOTIOJtilki5WW-9.00t:
Page 11
HOUSE OVERSIGHT 012406
-0929104.TXT
14
1 A. After it happened.
2 Q. You know that he had press conference
3 don't you, yes or no?
4 A. ISI
5 Q. In fact, let's go to Exhibit 20-01.
6 MR. GOLDBERGER: Look behind you. You'll
7 see it.
8 BY MR. TEIN:
9 Q. Have you ever seen that picture before?
10 A. Yes.
11 Q. Is that a picture of your father, your
12 stepmother and Mr. Herman at the press conference
13 regarding your lawsuit?
14 A. Yes.
15 Q. Now you know that this is a very serious
16 matter, don't you?
17 MR. LEOPOLD: Asked and answered.
18 Objection.
19 MR. GOLDBERGER: All right. You can
20 object. You're representing a witness here,
21 Mr. Leopold. You can object on privilege grounds.
22 You cannot make legal objections. You have no
23 standing to do so.
24 MR. LEOPOLD: I'm going to make them and
25 then --
15
1 MR. GOLDBERGER: We're --
2 MR. LEOPOLD: We're going to leave or we're
3 going to take a break because his demeanor is not
4 appropriate. There's no reason to have this kind
Page 12
HOUSE OVERSIGHT 012407
-0929104.TXT
5 of demeanor. If you want to have this kind of
6 demeanor with me
7 MR. TEIN: You are obstructing this
8 deposition.
9 MR. GOLDBERGER: Why don't you guys go
10 outside and just talk about --
11 MR. LEOPOLD: She -- her job is very
12 difficult and she's not going to be able to take
13 us both talking at he same time.
14 MR. GOLDBERGER: Off the record.
15 MR. LEOPOLD: We're not going off the
16 record, Jack. We're not, Jack. Her job is very
17 difficult. I'm going to make the record.
18 I don't think it is appropriate, especially
19 in the small confines of this room, to be very
20 aggressive with this young lady.
21 MR. TEIN: That's not happening. Stop,
22 stop actually --
23 MR. LEOPOLD: If you're going to interrupt
24 me, we're going to cancel this deposition --
25 MR. TEIN: Stop misrepresenting.
16
1 THE COURT REPORTER: I need on at a time,
2 no matter who it is.
3 MR. LEOPOLD: I think we're going to take a
4 break. Perhaps you might want to talk to your
5 co-counsel --
6 MR. TEIN: I don't need to talk to him.
7 MR. LEOPOLD: But we're going to take a
8 break.
Page 13
HOUSE OVERSIGHT 012408
-0929104.TXT
9 MR. TEIN: Not taking a break unless the
10 witness needs a break.
11 You're obstructing this deposition, Ted.
12 MR. LEOPOLD: Come on,
13 You all want to continue in this
14 demeanor --
15 MR. TEIN: You're obstructing the
16 deposition. Stop making speeches. We're not
17 discussing this with you. The questions are to
18 your client. Go take your five-minute break.
19 MR. LEOPOLD: Fine. We need to make sure
20 the record's clear and clean.
21 And I want to make sure as I've already
22 asked you -- I know that you're one of the best in
23 town -- that this audio -- this needs to be
24 preserved. Okay?
25 MR. TEIN: Go take your five-minute break,
17
1 Mr. Leopold, now.
2 You were supposed to be here at nine a.m.;
3 it's now after two. Take your break and come
4 back.
5 MR. LEOPOLD: Okay. If the demeanor keeps
6 up, we will not be here beyond those five minutes.
7
8
9 relax.
10
11 break.
MR. TEIN: Take your break and come back.
MR. LEOPOLD: Okay. So I suggest that you
MR. TEIN: I suggest that you take your
12 MR. GOLDBERGER: Let them take that
13 five-minute break.
Page 14
HOUSE OVERSIGHT 012409
-0929104.TXT
14 MR. LEOPOLD: But I would suggest that you
15 take deep breaths.
16 MR. TEIN: Suggest whatever you want. Go
17 take a break.
18 (Thereupon, a recess was taken.)
19 BY MR. TEIN:
20 Q. you agree that giving testimony
21 today at your deposition is something very serious, don't
22 you?
23 A. Yes.
24 Q.
25 A.
ANT 5i.000%.5
WO_ 40m
1 Q. Let me show you Exhibit 31-001. Can you
2 read that out loud, please?
3 A. Okay. What do you want?
4 Q. Will you read that out loud, please.
5 A. Oh.
6 Q. Thank you.
7 A.
M*1
hati MOW
3g.:4
On WOOt
00310.04.
Like after so long wow
18
10 im sorry... well yah well we will definitely havta make
11 plans for sure. .because i miss u tons times a million and
12 no no no i love you...o p.s. i love ur default pic
13 niggaa. Muah xo.
14 Q. Did you send that message last week to a
15 friend of yours on MySpace?
16 A. I wouldn't know. There's no dates and I've
17 deleted that MySpace, so --
Page 15
HOUSE OVERSIGHT 012410
-0929104.TXT
18 Q. Were going to talk about that in a second.
19 A. Okay.
20 Q. Did you send that message last week
21 A. Right.
22 Q. Let me finish my question.
23 Did you send that message last week to a
24 friend of yours on MySpace?
25 A. I wouldn't know the date, but obviously,
19
1 it's to a friend.
2 Q. q NOW A 400$0g m110
3 loPMPOAMYWOOZ
4
7
8
9
10
11
12
13 THE WITNESS: Are you referring to
14 anything --
15 MR. LEOPOLD: No, Don't -- don't --
16 let him ask you the question.
17 BY MR. TEIN:
18 Q. What question were you asking..
19 MR. LEOPOLD: She doesn't ask questions.
20 You ask the questions. What is the question
woimyov:
vIroforriog,to thisA0poItton7;
YO:
Q. Do you find the term n-i-g-g-e-r offensive?
A. That's not anywhere in there.
Q. What word did you use in there?
MR. LEOPOLD: Where are you referring to,
Counsel? There's 20 plus words in there.
MR. TEIN: Don't make a speaking objection.
21 pending?
22 BY MR. TEIN:
Page 16
HOUSE OVERSIGHT 012411
-0929104.TXT
23 Q. what is the last word on there in
24 the text of your message before the closing?
25 A. Niggaa.
20
1 Q. Don't you find that term offensive?
2 A. No.
3 MR. LEOPOLD: Can you spell it for the
4 record, please.
5 THE WITNESS: N-i-g-g --
6 MR. TEIN: No, no, no. You are not going
7 to be asking questions.
8 MR. LEOPOLD: I'm not asking questions.
9 I'm asking for the record the word to be spelled
10 because we don't have a video here today.
11 MR. TEIN: These exhibits are part of the
12 record. You --
13 MR. LEOPOLD: Well, it's not marked as an
14 exhibit.
15 MR. TEIN: Stop interrupting me,
16 Mr. Leopold. I have marked and identified as an
17 exhibit and you will get it.
18 MR. LEOPOLD: There has been no
19 identification of this document in the record.
20 MR. TEIN: Mr. Leopold, stop interrupting
21 this deposition
22 MR. LEOPOLD: What is the exhibit number
23 marked for identification?
24 MR. TEIN: 31-001.
25 MR. LEOPOLD: Do we have copies? Is it on
Page 17
HOUSE OVERSIGHT 012412
-0929104.TXT
21
1 the record anywhere?
2 BY MR. TEIN:
3 Q. Let me ask you, did you in fact
4 write your friend this message about this deposition?
5
6
7 40
8 A. Yes.
9 Q. Because you think this deposition is stupid
10 court s-h-i-t, don't you?
11 A. No.
12 Q. You wrote that to your friend, didn't you?
13 A. Yes.
14 Q. You think that court is stupid, don't you?
15 A. In some cases.
16 Q. And you think that court is bull s-h-i-t,
17 don't you?
18 A. No.
19 Q. And you think this deposition is bull
20 s-h-i-t, don't you?
21 A. No.
22 Q. You wrote that to your friend, didn't you?
23 MR. LEOPOLD: Objection. Asked and
24 answered.
25 MR. TEIN: That's not an objection.
A.
Q.
positio
Yes.
'00gWrOtO 15100
stupid400
deamutttio
22
1 BY MR. TEIN:
2 Q. You wrote that to your friend, didn't you?
3 MR. LEOPOLD: Objection. Asked and
4 answered, for the fourth time.
Page 18
HOUSE OVERSIGHT 012413
-0929104.TXT
5 MR. TEIN: You are improperly objecting,
6 Mr. Leopold. You have no grounds to object. And
7 that's not an objection.
8 MR. LEOPOLD: It is an objection.
9 MR. TEIN: Then terminate the deposition if
10 you think it's been asked and answered.
11 MR. LEOPOLD: Counsel, I am not precluded
12 from just making an objection to the form of the
13 question. As the courts well know, and if you
14 practice here in West Palm Beach, many of the
15 judges require you to set the objection with
16 specificity. And I will do that. And if you
17 don't want me to, you can make the record. But I
18 will do that.
19 MR. TEIN: Here's what we'll do, Ted. You
20 can -- I will allow you to reserve an objection to
21 form for every single one of my questions.
22 Otherwise, all you're doing is obstructing.
23 MR. LEOPOLD: I won't do that.
24 MR. TEIN: Of course; because you want to
25 obstruct.
23
1 MR. LEOPOLD: All right.
2 BY MR. TEIN:
3 Q. Saige, you think that giving testimony
4 today, under oath, is bull s-h-i-t, don't you?
5 A. No.
6 Q. And you wrote that to your friend on
7 MySpace last week, didn't you?
8 MR. LEOPOLD: Objection. Asked and
Page 19
HOUSE OVERSIGHT 012414
-0929104.TXT
9 answered.
10 THE WITNESS: No, 1 did not.
11 BY MR. TEIN:
12 Q. You didn't write this exhibit?
13 A. I wrote that, but I didn't write what you
14 said.
15 Q. You wrote in this exhibit, "I got some
16 stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't
17 you write that?
18 A. Yes.
19 Q. Referring to this deposition, didn't you?
20 A. Referring to the court. I was later
21 informed that it was a deposition.
22 Q. I'm going to ask you some questions now
23 about what happened when you went to Jeff Epstein's house
24 three years ago. Okay?
25 A. Uh-huh.
Q VOMMO4OF
24
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5
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4a NOR, AbOBEW*TfN00.0002 4N000010M0ft
8 tied sex with hI
aa 500011W house take you comIeteTyiiibygg
Ii A. Yes
12 Q. Now the civil complaint that you filed
13 against Mr. Epstein for fifty million dollars alleged
Page 20
WOW MOMMEht
eff
HOUSE OVERSIGHT 012415
-0929104.TXT
14 that you were totally shocked by what happened when you
15 got there.
16 A. Yes.
17 Q. Were you totally shocked by what happened
18 when you got to Epstein's house?
19 A. Yes.
20 Q. You didn't expect it at all, did you?
21
22
A.
No.
)1.0.0;1144.441).$0.Mrat/g00:3400AWiSfOgg.ftt010-
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6
7
11
12 engage in any sexual activity with Epstein?
13 A. No.
14 Q. Did Anthony every try to convince
15 you to engage in any sexual activity with Epstein?
16 A. I don't know who Anthony is.
17 Q. Do you have a friend Anthony?
Page 21
A.
house
0151INOWaVaitiN#XVO.Iii
No.
And b440410POPAROPOIPWWW
never sent yo a message100MONTOtOtk,
... activity 0 Epstein, did
Q. Did Zack ever try to convince you to
HOUSE OVERSIGHT 012416
-0929104.TXT
18 A. No.
19 140 :ONOYiN
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22
23
24 UnOfillMihaW0A0000TOOdgt0g1405$04
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1
2
3 again.
4
UnOW
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7
14
15 objection for the record.
16 MR. TEIN: Stop speaking.
17 MR. LEOPOLD: I'm not going to stop
18
19 the record.
20 MR. TEIN: You're coaching the witness.
21 MR. LEOPOLD: Counsel --
22 MR. TEIN: Stop coaching the witness.
Page 22
NO:.
gg *OIL
Q.
dowAi
U. tooigàge In
26
You're sure that -- let me ask the question
Yd a. tibt 00f6MVOW-4Mtd;
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a
de you to engago
MR. LEOPOLD: Objection. Asked and
8 answered.
9 THE WITNESS o And I've already
10 answered that a bazillion times.
11 BY MR. TEIN:
12 Q. He's coaching you now. So I'm going to ask
13 the question --
MR. LEOPOLD: Counsel, I've made an
speaking. You can't interrupt me when I'm making
HOUSE OVERSIGHT 012417
-0929104.TXT
23 BY MR. TEIN:
24 Q. let me ask you --
25 MR. LEOPOLD: If you continue to --
27
1 MR. TEIN: Stop interrupting my questions.
2 MR. LEOPOLD: If you do it one more time,
3 we're leaving.
4 BY MR. TEIN:
5 Q.
6 MR. LEOPOLD: I'm going to make the record.
7 You cannot interrupt me when I'm making the
8 record. Out of professional conduct, you cannot
9 do that. I'm entitled to make the record. I made
10 an objection, asked and answered. You demeanor is
11 inappropriate. You're willing and you are able
12 and you're responsible to ask a question in a
13 professional manner and ask the question and once
14 you get the answer, to either follow up on it or
15 move on, but not continuously browbeat and ask the
16 same question over and over because you don't like
17 the answer.
18 MR. TEIN: Calm down, sir.
19 MR. LEOPOLD: Trust me, I'm very calm here.
20 When I'm not calm you'll know it. I'm very calm.
21 So please continue on, but I will not allow
22 you to continue to harass her in the demeanor that
23 you're doing. Ask her a question and move on.
24 MR. TEIN: Are you done?
25 MR. LEOPOLD: Thank you. I am.
Page 23
HOUSE OVERSIGHT 012418
-0929104.TXT
28
1 MR. TEIN: Stop misrepresenting the record
2 and calm down. I'm going to ask my question.
3 Stop it.
4 BY MR. TEIN:
5 Q.
6 MR. LEOPOLD: I think the record is very
7 clear.
8 MR. GOLDBERGER: Let me just clarify
9 something. When you object to the form of a
10 question, you're not instructing the witness not
11 to answer the question, are you?
12 MR. LEOPOLD: No. And I'm not making that
13 objection: only on attorney/client privilege.
14 MR. TEIN: Will you stop speaking now so I
15 can ask my question? Are you done?
16 Okay. I'm going to ask my question.
17 BY MR. TEIN:
18 Q. Listen,
19 MR. LEOPOLD: Hold on. Stop.
20 I've been doing this for 20 plus years and
21 have met a lot of attorneys, but I've never had an
22 experience like this where I've --
23 MR. TEIN: Stop your speeches.
24 MR. LEOPOLD: If you continue to do this,
25 whether its with me or with my client, I will not
29
1 put up with it and I don't need to put up with it
2 and it's not appropriate. And I'm sure Mr.
3 Goldberger knows all this, because I know that he
4 wouldn't do this. So I will not put up with it.
Page 24
HOUSE OVERSIGHT 012419
21
22
23
24
25
1
3
1:$
5
6
-0929104.TXT
And I think it's highly inappropriate to do this
with this child sitting here, the way you're
7 acting, primarily towards me, and I will not put
8 up with it.
9 MR. TEIN: Will you please stop your speech
10 so I can ask questions?
11 MR. LEOPOLD: So long as you act
12 professionally, I will do so. But if you continue
13 to do it this way, I will leave.
14 MR. TEIN: Suit yourself.
15 BY MR. TEIN:
16
la
are you sure that brore you go:t.
ie tried to..."TttUalCSO.40.3Migtr.1
$0001g6M9440Witft 'gtb4W bitHM40/7
19 MR. LEOPOLD: Asked and answered.
20 Objection.
MR. TEIN: Did you get her answer?
THE COURT REPORTER: No, I did not.
THEATINEW
*A000100gA000400
BY MR. TEIN:
OtH0080
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30
e41.
Or
Q Jeff never e-rnai led you, dd he?
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Page 25
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HOUSE OVERSIGHT 012420
-0929104.TXT
1
2
A.
Q.
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..............................................................................................
ad you
And  you only went
that one time three years ag, correct?
A.
Yu never went there again,
A. No.
taiiiaariiitpAtOtdaZba1$0
tt:Odt2i-
Q. All right. Let me ask you two final areas
3 of questioning about this and we'll move onto something
4 else. Okay?
5 A. Uh-huh. Yes. I'm sorry.
6 moggrommok -WOMOOW
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-m50:-Im!:14-gr$oaaceiiitit113.0
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erce you to engage
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Page 26
31
HOUSE OVERSIGHT 012421
-0929104.TXT
14 engage in any sexual activity?
!;IS
Q.
5WW.OTWYOdttOt
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Min
20 Q. Was it or was it the other girl in
21 the car who you rode over with to Epstein's house?
22 A.
23 Q. Who was the other girl in the car with you
24 that day?
25 A. I honestly don't know.
32
1 Q. Had you ever seen her before?
2 A. No, sir.
3 Q. You told the police that when you rode over
4 to Epstein's you had no idea who she was, right?
5 A. Correct.
6 Q. You told the police that you didn't know
7 her name, but she was like really dark, kind of like a
8 Spanish girl?
9 A. Yes.
10 Q. Those were your words, right?
11 A. Yes.
12 Q. Do you now know who she is?
13 A. No, sir.
14 Q. So it was who told you to lie about
15 your age to Jeff Epstein?
16 A. Yes, sir.
17 Agt A0410400Ahlk Page 27
27
HOUSE OVERSIGHT 012422
-0929104.TXT
18 hoL
19
20
21 when you first met Jeff. Okay?
22 A. Sure.
23 Q. When you first met Jeff he tried to find
24 out how old you were, right?
25
300MERMY0040$0
Q. All right. Let's talk for a minute about
A. Excuse me?
33
1 ' 000#000; hONtd#0400400)
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3 Not. whrW fi rsti................rtrodUd P4OWMOr
4 WOht AMter$40X4MY:
5 Q. During the massage Jeff asked you how old
6 you were, correct?
7 A. Yes, yes.
8 Q. Now hadn't you already told Jeff's
9 assistant, the one who walked you upstairs, that you went
10 to college and had just moved down here from Ohio?
11 A. I never spoke to the lady.
12 Q. Do you want to rethink that answer?
13 MR. LEOPOLD: Is that a question?
14 BY MR. TEIN:
15 Q. Do you want to rethink that answer?
16 A. No. I didn't really speak with her that
17 much.
18 Q. Do you want to try to refresh your memory
19 on that?
20 MR. LEOPOLD: Do you have something to
21 refresh her memory with?
22 MR. TEIN: Do you want to stop making
Page 28
HOUSE OVERSIGHT 012423
-0929104.TXT
23 speaking objections?
24 MR. LEOPOLD: No. But to refresh someone's
25 memory you show them a document.
34
1
2
3
4
5
6
7
MR. TEIN: I know how to do this.
MR. LEOPOLD: Then show her a document.
MR. TEIN: Stop speaking.
MR. LEOPOLD: I'm not going to stop
speaking. I'm going to continue to make the
record.
MR. TEIN: You're obstructing. Please
8 stop.
9 MR. LEOPOLD: I'm not obstructing. But if
10 you want to refresh her recollection, you need to
11 show her something.
12 That's not a proper question. I object to
13 the foundation and the predicate of that question.
14 MR. TEIN: Are you done?
15 MR. LEOPOLD: I am now. Thank you.
16 BY MR. TEIN:
17 Q. Do you want to try to refresh your memory
18 as to whether you had any conversation with the woman who
19 walked you upstairs in Epstein's house in which you told
20 her that you went to college and had just moved down from
21 Ohio?
22 MR. LEOPOLD: Objection. Object to the
23 form of the question. Lack of foundation and
24 predicate.
25 BY MR. TEIN:
Page 29
HOUSE OVERSIGHT 012424
-0929104.TXT
35
1 Q. You can answer the question.
2 A. Sure.
3 Q. Is there anything that would refresh your
4 memory that in fact you told Mr. Epstein's assistant, the
5 one who walked you upstairs, that you went to college and
6 you had just moved down here from Ohio?
7 A. I don't remember saying that, but if you
8 I don't remember saying that myself, so --
9 Q. That would be a lie, right?
10 A. No. I really don't remember.
11 W WNW Ri Jeff that you weragInf
10-,L gOttOM
13 YO*0
14 Q. Do you remember Detective Michelle Pagan of
15 the Police Department, Palm Beach Police Department?
16 A. Yes.
17 Q. Do you remember you spoke to her?
18 A. Yes.
19 Q. Do you remember that you told Detective
20 Pagan igogp_....................................................... Wppj$4tdatiOUWWW-  :thJf1HVoUrdi
....... MOtbaWOMitti.0040$0400
22
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00§WR
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25 Q. And do you remember telling Detective Pagan
.i$ound,
36
1 that when you lied to Epstein about your age that you
2 said it really fast so Epstein wouldn't realize you were
3 lying?
4 A. No, I don't remember saying those words
Page 30
HOUSE OVERSIGHT 012425
-0929104.TXT
5 exactly to her. 3-gtoioobotawmgatgaiampao
44XPTIVAMMOWTOZ
7 Q. Does it sound right to you that you told
8 Detective Pagan that you said your age really fast to
9 Epstein
10 MS. BELOHLAVEK: Objection. Asked and
11 answered.
12 BY MR. TEIN:
13 Q. -- so he wouldn't think that you were
14 lying?
15 MR. LEOPOLD: Objection. Asked and
16 answered, lack of foundation, mischaracterization
17 of her earlier testimony. She's already answered
18 that question.
19 BY MR. TEIN:
20 Q. You can answer it.
21 MR. LEOPOLD: Same objection. It's been
22 asked and answered.
23 You can answer. I've made the objection.
24 THE WITNESS: I forget the question, now.
25
37
1 BY MR. TEIN:
2
3
4
7
8
Q. Let me put it again.
P9g*iiPg$01400:gr*OggPgYOm 4;.!ggo.lo
;!pgpootif:MgRggpmingvmhowa. I,:ttWoh•otrPsoutuogmixo
ia.Orte#SC'!EPt#T:ff.!;:i*O2i$'4'itt:i!!trAt:0:44:1ISC:r.O$M;ti.O.g0::(1:11.
4146AtAbbtg iff6M4V
8-0
MR. LEOPOLD: Objection.
foundation, asked and answered.
Page 31
HOUSE OVERSIGHT 012426
9
44
11 BY MR. TEIN:
12
-0929104.TXT
3#,RIMEMPAt
f0.00X1J
:ro.:,,,:lylog*i.04t1Yourogg:15401tz
-#Z 00t0.0t
15 Q YOM0140MOOVI.,Mr Epstein to know that
T uwot.i8.zitTgbtZ:
::POtPOOtM:
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Hy were is, right?
24   Wh e   Ak ,   Correct. Do you remember when Mr. :g4tfl omooto school? Aritd1iMr Epstein Y0 ONWOWXR right?
38
1   A.   Yes.
2   q.   Was that thGxpowz, W
4   Q.   In fact, you went to   right?
5   A.   Yes.
6   Tm   wsc- Tiedgzogyi 01.#1540PrOOPZ.
006
8   Q.   Is Wellington the college that you told
9   Jeff's assistant that you were attending?
10   A.   I don't remember having that conversation
11   with her, so I wouldn't know if that's what I said.
12   Q.   That was a lie, though, wasn't it?
13   MR. LEOPOLD: Objection to the form of the
Page 32
HOUSE OVERSIGHT 012427
-0929104.TXT
14 15 16 17   question, lack of foundation. You're making an assumption. She just answered you she can't tell you that. MR. TEIN: Speaking objection. And you
18   well know that, Mr. Leopold.
19   MR. LEOPOLD: She can't answer that
20   question. The way you phrased that question
21   you're purposely making her not be honest in her
22   testimony. She can't answer a question like that.
23   She doesn't remember So then you say, "So you
24   were lying." That's improper and you know that.
25   That's not a proper question. And any attorney
39
1   that would do that to a witnesses or to a person
2   that's sitting in this chair is not acting
3   professionally. You can't ask a question like
4   that. You can do it, but it's not proper. And
5   I'm sure you weren't trained that way, certainly
6   not ethically.
7   MR. TEIN: Will you stop?
9   MR. LEOPOLD: I'm not going to stop, because the way you're asking that question is
10   improper and you know it.
11   MR. TEIN: You're losing your cool.
12   BY MR.   TEIN:
13   Q.
14   MR. LEOPOLD: Trust me. I'm very calm.
15   When I   lose my cool, you'll know it.
16   MR. TEIN: I do know it.
17   BY MR.   TEIN:
Page 33
HOUSE OVERSIGHT 012428
104. TXT
18 •:Q,.11it Mr'r:::'.1::Eri:$K%Olii.009:0.n!..0-$.-gOtlz-S0,0:-
Ta ,K.Mii:.....M6:01110M0100t:!kititiaiiiit05$4402.1.1110igi00.C100-gitZ
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25
.hI1:her
MR. LEOPOLD: Objection. Foundation,
40
predicate.
THE WITNESS: Correct.
You toldthe p01 lce :A*Otatg#00Matbbt
him 46....2.4V-
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IA00$MOOMMOOtai:
Your ggr NOM4OggIXbOX%M040
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MMIAINKOIPMPOMOMMOMAI4MMY
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At no time di
did you?
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114 'AMEXWOW
I ncorrect.
Well, you told the police, "At no time did
Page 34
HOUSE OVERSIGHT 012429
-0929104.TXT
23 he touch me." Were you lying to the police then?
24 A. No. Well, I wasn't being fully truthful,
25 but I wasn't lying.
41
1 Q. You told the police twice when you spoke to
2 Michelle Pagan that "at no time did he touch me." Didn't
3 you say that to the police?
4 A. Yeah.
5 Q. And you're saying that that was not fully
6 truthful. Is that what you're saying now?
7 A. Correct.
8 Q. And you're saying if you're not fully
9 truthful, that's not a lie. Correct?
10
14
15
16
17
18
todu
47@ga
A. YOU t001( that 01..rt of context I 4C4Wrea 1
didn-tt an lIke that. Touching my legSsand --
kePtlilhands to himself tile entire time.
TWV
to
Q. You told the police, "At no times did he
touch me." You agree with that, correct?
A. No, I don't agree with that, because he did
touch me.
Q. Did you tell the police that he did not
19 touch you, yes or no?
20 A. It's a possibility, but I do not remember.
21 ,(W A60400HOUIROWNVOROYA9W0f3WO
VIVT 4OrCIR4611I0Ota
23
24
POz.
W AWN01414-
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Page 35
Y tYPe of ora sax
HOUSE OVERSIGHT 012430
4
Q.
-0929104.TXT
42
1
440394100§f-
POROME:
All right.
afEattdOtTi
Let's talk about what happened
5 after the massage was over.
6
7
A. Okay.
Q. After the massage you told Epstein that you
8 wanted to bring your twin sister back so she could make
9 some money, correct?
10 A. Incorrect.
11 Q. Your twin sister is , right?
12 A. Correct.
13 Q. And you love very much, don't you?
14 A. Yes.
15 Q. And when you left the house you were joking
16 with the other girls, weren't you?
17 A. Incorrect.
18 Q. Well, when and the other girl in the
19 car that day made their statements to the police they
20 told the police that you were joking afterwards. Are you
21 saying that they were lying to the police about that?
22 A. No. But a question or -- questions from
23 -- like she asked me questions, but it wasn't
24 joking. She was kind of like in a happy way, like, "Oh,
25 what did you do? What did you do?" Like those kind of
1 things, but it wasn't joking about it at all.
2 Q. You joked about it, didn't you?
3 A. No.
4 Q. You said to that if you did this
Page 36
43
HOUSE OVERSIGHT 012431
-0929104.TXT
5 every weekend you'd be rich, didn't you?
6 A. No. That's what told me.
7 Q. You didn't tell that to =?
8 MR. LEOPOLD: Objection. Asked and
9 answered.
10 THE WITNESS: No.
11 BY MR. TEIN:
12 W AMMMYOWTOMEO - '''' :,1000$040w With0-
gi *MVO OIMINA04....
14 4W-EtwthONOVezorpootiz
15 A. Incorrect. I didn't spend any of the
16 money.
17
18
19
21
22
23
24
Q. You went to Marshall's, didn't you?
A. I went along, yes, but I didn't --
T003000AAMOROWANMANOWOMMOMM
4.
MR. LEOPOLD: Objection.
THE WITNESS: I guess you could say that.
MR. LEOPOLD: Objection. Lack of predicate
and foundation. Mischaracterization of earlier
25 testimony.
1 BY MR. TEIN:
2 Q. And bought a purse, right?
3 A. Yes.
4 Q. And you were with her the whole time at
5 Marshall's, correct?
6 A. Yes.
7 Q. Now tell me about when the federal
8 prosecutors told you about getting reimbursed.
Page 37
44
HOUSE OVERSIGHT 012432
-0929104.TXT
9 A. I have no idea what you're talking about.
10 Q. Tell me about when the federal prosecutors
11 spoke to you about getting money you feel you're entitled
12 to from Mr. Epstein.
13 A. I don't know what you're talking about.
14 Q. Do you know who Marie Villafona is?
15 A. No, sir.
16 Q. Did you ever meet with any federal
17 prosecutors?
18 A. I think -- yeah. I think they were -- I
19 think they were like FBI.
20 Q. Uh-huh. Did you meet with federal
21 prosecutors?
22 A. They came to my house one time, yes.
23 Q. When did they come to your house?
24 A. Very long ago.
25 Q. Was it this year, 2008?
45
1 A. It was not this year, no.
2 Q. Was it 2007?
3 A. I'd have to say at least two years ago or a
4 year ago, yeah. So it would be 2007, 2006; but it was a
5 while ago.
6 Q. How many federal prosecutors or FBI agents
7 came to your house?
8 A. I'm trying to remember. I want to say four
9 people came.
10 Q. Did they give you their business cards?
11 A. If they did, I don't remember, and they
12 weren't toward me. Maybe my parents have them. I don't
13 know.
Page 38
HOUSE OVERSIGHT 012433
-0929104.TXT
14 Q. Did they give you their cell phone numbers?
15 A. No
16 Q. Did you ever speak to them on their cell
17 phones?
18 A. No, sir.
19 Q. Did they speak to your parents?
20 A. That's something you'd have to ask my
21 parents.
22 Q. Do you know whether they spoke to your
23 parent's?
24 A. No, sir.
25 Q. You have no idea?
46
1 A. No, sir.
2 MR. LEOPOLD: Objection. Asked and
3 answered.
4 BY MR. TEIN:
5 Q. So if I say the name to you Marie
6 Villafona, you don't know who that is?
7 A. No, sir.
8 Q. How many women and how many men came to
9 your house?
10 A. I want to say two ladies and two guys.
11 Q. Did someone named Jeffrey Sloman come to
12 your house?
13 A. I don't know names, sir.
14 Q. Do you know who Jeffrey Sloman is?
15 A. No, sir.
16 Q. Do you know who Jeffrey Herman is?
17 A. Yes.
Page 39
HOUSE OVERSIGHT 012434
-0929104.TXT
18 Q. That's the lawyer who first sued Epstein on
19 your behalf, right?
20 A. Yes.
21 Q. Has Mr. Herman advanced your family any
22 money?
23 MR. LEOPOLD: Any conversations that you've
24 had with Mr. Herman regarding that issue, you are
25 not to disclose. If you've learned in some other
47
1 fashion, you may answer.
2 THE WITNESS: Okay.
3 I wouldn't know.
4 BY MR. TEIN:
5 Q. You don't know?
6 A. No.
7 MR. LEOPOLD: Objection. Foundation.
8 Attorney/client privilege.
9 BY MR. TEIN:
10 Q. And you say you don't know who Jeff Sloman
11 is?
12 A. No, sir.
13 Q. Does it refresh your recollection that he's
14 the number two prosecutor at the U.S. Attorney's Office?
15 A. No.
16 Q. That he's Marie Villafona's boss?
17 A. No.
18 Q. Does it refresh your memory that he's the
19 ex-partner of Jeff Herman, the first lawyer who sued
20 you -- sued Mr. Epstein on your behalf for fifty million
21 dollars?
22 A. No. I don't know who he is.
Page 40
HOUSE OVERSIGHT 012435
-0929104.TXT
23 Q. Without telling me any conversations that
24 you've had with your lawyers, how is it that you selected
25 Mr. Herman as your lawyer from the 81,000 members of the
48
1
2
3
4
5
6
7
Florida Bar?
A. I did not select him.
Q. Who did?
A. My father.
Q. Did you ever meet Mr. Herman?
A. Once.
Q. Don't -- don't tell me what you discussed
8 with him. Where did you meet him?
9
10 friend's house.
11 Q. Whose house?
12 A. My friend
13 Q. Is that from
14
15
16
17
18
19
A. I was shopping in my -- he showed up at my
A. Yes.
Q. And did you have a meeting with him at
's house?
A. Yes. I guess you could say that.
Q. And who else was there?
20 A. My Aunt
21 Q. And what was that meeting about?
22 MR. LEOPOLD: Objection. That calls for
23 attorney/client privilege.
24 BY MR. TEIN:
25 Q. What discussions did you have with
Page 41
HOUSE OVERSIGHT 012436
-0929104.TXT
49
1 Mr. Herman in the presence of
2 A. None.
3 Q. What discussions did you have in the
4 presence of her aunt?
5 A. Of my aunt?
6 MR. GOLDBERGER: It's the witness's aunt.
7 BY MR. TEIN:
8 Q. Oh, of your aunt.
9 A. The only one that we've ever discussed or
10 ever had.
11 Q. And so you were in a conversation with
12 Mr. Herman and your aunt?
13 A. Yes, sir.
14 Q. And you discussed privileged matters during
15 that conversation?
16 MR. LEOPOLD: Object to the form. I think
17 you might have to educate her on that question.
18 BY MR. TEIN:
19 Q. You discussed the lawsuit?
20 A. Yes.
21 Q. Did tell you about any
22 conversations that she had with Mr. Herman?
23 A. As far as I'm concerned, she's never spoken
24 or she's never had a conversation. She only opened the
25 door and then left. She's the one who answered the door.
50
1 Q. Why did the meeting take place at
2 house?
3 A. I spent the night that night at her house.
4 Q. And when was this?
Page 42
HOUSE OVERSIGHT 012437
5 A.
6 Q.
7 A.
8 Q.
9 A.
10
11
12
13
14
15
16
-0929104.TXT
A while ago.
How long ago?
A month and a half ago. I'm
A month and a half ago?
Uh-huh.
:WWWJMOWOMOVAMOVAIna
guessing.
ottotattriA0.0..
4W ABM
Q. Did you meet what an FBI agent named Nesbit
Kirkendall, a woman?
A. I don't know.
Q. Did Ms. Kirkendall speak to you about
17 getting reimbursed from Mr. Epstein?
18
19
20
21
22 A. Not to my knowledge.
A. I've never had a discussion with anyone
about getting reimbursed from Mr. Epstein.
Q. Have you met with an agent named Jason
Richards?
23 Q.
24 A.
25 Q.
How about an agent named Tim Slater?
No, sir.
How about an agent named Junior Ortiz?
51
1 A. No.
2 Q. And we've learned that many of the girls,
3 some of whom are as old as 23, were told by the
4 government that they would get money at the end of the
5 criminal prosecution. Does that sound familiar to you?
6 A. No, sir.
7 Q. Other than Mr. Leopold here I'm not
8 asking about Mr. Herman either --
Page 43
HOUSE OVERSIGHT 012438
-0929104.TXT
9 A. Uh-huh.
10 Q. -- did anyone ever discuss with you that
11 you could get reimbursement for your damages?
12 A. No, sir.
13 Q. Did you or any member
14 MR. LEOPOLD: Are you referring to a
15 criminal matter or a civil matter?
16 BY MR. TEIN:
17 Q. Did you or any member --
18 MR. LEOPOLD: Excuse me. Let me object to
19 the form of the question.
20 BY MR. TEIN:
21 Q. Did you or any member of your family ever
22 get a victim notification letter from anyone?
23 A. I no longer live at that residence and I
24 wouldn't know.
25 Q. So your testimony is that you have never
52
1 received a victim notification letter, correct?
2 A. Correct.
3 Q. And your testimony is that you don't know
4 if your parents have ever received a victim notification
5 letter, correct?
6 A. Correct.
7 Q. Have you given any evidence to prosecutors
8 or law enforcement in this case?
9 A. What do you mean by evidence?
10 Q. Well. Anything that you can touch or feel?
11 A. No.
12 MR. LEOPOLD: Objection to the form of the
13 question.
Page 44
HOUSE OVERSIGHT 012439
-0929104.TXT
14 BY MR. TEIN:
15 Q. So you haven't given anything physical --
16 A. No.
17 Q. -- any item to any prosecutor, police
18 officer or law enforcement agent, correct?
19 A. My cell phone four years ago or three years
20 ago, but that's it.
21 Q. You gave your cell phone to whom?
22 A. Michelle Pagan.
23 Q. Did she keep it?
24 A. Ask her.
25 Q. You gave it to her and then you didn't get
53
1 it back at the end of the meeting?
2 A. No. They -- yeah. No. They have it. I'm
3 guessing. I don't have it.
4 Q. How much money are you hoping to get out of
5 Mr. Epstein?
6 MR. LEOPOLD: Objection to the form of the
7 question. Attorney/client privilege.
8 BY MR. TEIN:
9 Q. How much money are you hoping to get, you,
10 yourself, hoping to get out of Epstein?
11 MR. LEOPOLD: Same. Same objection,
12 attorney/client privilege.
13 Don't answer the question.
14 BY MR. TEIN:
15 Q. I'm not asking about what your lawyer told
16 you.
17 MR. LEOPOLD: I'm instructing her not to
Page 45
HOUSE OVERSIGHT 012440
-0929104.TXT
18 answer the question, because any of those
19 conversations involve her counsel.
20 MR. TEIN: Certify that.
21 MR. LEOPOLD: Please.
22 ..................CERTIFIED QUESTION..................
23 BY MR. TEIN:
24 Q. Now, Saige, you lied to get out of this
25 deposition, didn't you?
54
1 A. No, sir.
2 Q. You didn't want to come to court today and
3 tell the story that you had told to the police under
4 oath, did you?
5 MR. LEOPOLD: Object to the form of the
6 question. Lack of foundation, predicate.
7 THE WITNESS: No. I have no problem coming
8 here and talking to you.
9 BY MR. TEIN:
10 Q. And to avoid getting served with a lawful
11 subpoena, you lied about your name, didn't you?
12 A. No.
13 Q. And in fact, just lying yourself wasn't
14 enough, was it?
15 MR. LEOPOLD: Objects to the form of the
16 question.
17 Don't answer it. It's not a question.
18 Object to the form of the question. Lack
19 of foundation.
20 MR. TEIN: Are you instructing her not to
21 answer?
22 MR. LEOPOLD: I am.
Page 46
HOUSE OVERSIGHT 012441
23
24
25
-0929104.TXT
MR. TEIN: Certify it.
MR. LEOPOLD: Please.
55
1 ..................CERTIFIED QUESTION..................
2 BY MR. TEIN:
3 Q. You asked your co-workers
4 MR. LEOPOLD: It's vague and ambiguous.
5 BY MR. TEIN:
6 Q. You asked your co-workers at the
7 to lie for you, didn't you?
8 A. No. I informed my boss about what was
9 going on and he told me that he would help in any way
10 that he can.
11 Q. Okay. You got your friend to lie
12 by switching name tags with you, correct?
13 A. Incorrect. It was a coincidence that same
14 night she was not wearing her name tag; she was wearing
15 mine. But I was also not wearing -- I was wearing my
16 name tag. Everyone switches name tags. It just so
17 happens it was a coincidence that same night the people
18 came with the papers.
19 MR. TEIN: Will you put up Exhibit 18-001?
20 MR. GOLDBERGER: And mark 18-001 for
21 identification purposes to this deposition.
22 MR. LEOPOLD: None of them have been marked
23 yet. Can we mark them and put them as attachment
24 to the depositions? Because I think you've shown
25 three photos now. And this is the only one that
Page 47
HOUSE OVERSIGHT 012442
-0929104.TXT
56
1 has been marked for identification yet.
2 BY MR. TEIN:
3 Q.
4 MR. LEOPOLD: Hold on just a second. Just
5 so the record is clear --
6 MR. TEIN: I'm not speaking to you.
7 MR. LEOPOLD: Okay. Then don't speak to me
8 then. But I'll speak to Mr. Goldberger, perhaps.
9 But at least for the record, can we put on
10 the record what the previous two photographs were
11 marked for identification?
12 MR. GOLDBERGER: We will make sure that the
13 record is clear at the end of the deposition so
14 that there's no ambiguity.
15 MR. LEOPOLD: Thank you.
16 BY MR. TEIN:
17 Q. I've put a photograph marked 18-001
18 up on the screen. Do you see that?
19 A. Yup.
20 Q. Who is that in the photo?
21 A. on the left and me on the right.
22 Q. right?
23 A. Yes.
24 Q. your friend at the
25 right?
57
1 A. Yes.
2 Q. your friend, who you say the day
3 that the process servers went to serve you with a
4 subpoena for this deposition, just happened --just by
Page 48
HOUSE OVERSIGHT 012443
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
-0929104.TXT
coincidence, was wearing your name tag?
A. Yes, sir.
Q. And just by coincidence, you were wearing
her name tag, correct?
A. Yes.
Q. Your testimony under oath is that's just a
coincidence, right?
A. Total honesty.
Q. It just happens to be the day that you were
going to be served with a subpoena, correct?
A. That wasn't the first day that --
MR. LEOPOLD: just answer the
question. It calls for a yes or no.
THE WITNESS: Yes.
BY MR. TEIN:
Q. NOW$010gtb AMOOPritM
going to
000C90040,03
Gtflg
na
0150000WPOffrOW
A. c.dittotua
Q. 1650UKOWDOMM
00103
_AtON00
h that the process serve
58
1 looking for you, didn't you?
2 A. No. I knew --
3 MR. LEOPOLD: Just answer it. It calls for
4 a yes or no.
5 THE WITNESS: Okay. No.
6 BY MR. TEIN:
7 Q. Now you can explain the answer that your
8 counsel stopped you from explaining.
Page 49
HOUSE OVERSIGHT 012444
-0929104.TXT
9 A. Okay. I work at and people
10 were telling me that people were looking for me. So yes,
11 I was aware that people were searching for me, but I had
12 no idea who they were or what their intentions were, but
13 I thought they were just people I didn't want to talk to.
14 So I just didn't want to talk to them. And every time
15 they'd come to work I wasn't there. And so happens the
16 night that they came in me and my friend switched name
17 tags. No big deal.
18 Q. That's a lie, isn't it?
19 MR. LEOPOLD: Objection. Don't answer that
20 question. That's harassment and I will not allow
21 it. He could ask the questions and we'll allow a
22 jury to make that determination, but not counsel.
23 I will not allow her to answer that
24 question.
25 MR. TEIN: Certify it.
59
1 MR. LEOPOLD: I'll certify it.
2 ..................CERTIFIED QUESTION..................
3 She's answered that question. She's explained it five
4 times already. The fact that Counsel doesn't like the
5 answer, that's a different query.
6 MR. TEIN: Stop making speaking objections.
7 MR. LEOPOLD: I'm not. I'm not going to
8 put up with it, because it's in appropriate, Jack,
9 and you know it. I will not allow Counsel to
10 berate a witness, whether it's in a criminal case
11 or a civil case, whether my client or
12 MR. TEIN: Calm down.
13 MR. LEOPOLD: Excuse me.
Page 50
HOUSE OVERSIGHT 012445
-0929104.TXT
14 No, I'm not going to allow it. That is not
15 proper.
16 MR. GOLDBERGER: Okay.
17 MR. LEOPOLD: If he wants to say that she's
18 lying after asking it five times and her
19 explaining in great detail, he can do that. But
20 I'm not going to allow her to answer, nor be
21 harassed by him. It's improper.
22 MR. GOLDBERGER: Okay. But your response
23 that Counsel doesn't like the question -- or
24 doesn't like the answer -- just let me finish.
25 MR. LEOPOLD: Absolutely. I wasn't going
60
1 to interrupt you.
2 MR. GOLDBERGER: Just requires us to say we
3 like the answer to that question. And it's not
4 you and t or you and Mr. Tein who are testifying
5 here. It's the witness.
6 MR. LEOPOLD: Fine. But after the sixth
7 time of asking the same question and then coming
8 back and pointing a finger at her and saying,
9 you're a liar --
10 MR. TEIN: That didn't happen.
11 MR. LEOPOLD: That's fine. But I'm not
12 going to allow her to answer that question because
13 she's answered that same question and has
14 explained it.
15 Now Counsel might be sitting there rubbing
16 his head with a migraine. That's his problem.
17 But if he can't ask a question appropriately in a
Page 51
HOUSE OVERSIGHT 012446
-0929104.TXT
18 professional manner, we will leave. I will not
19 allow her to be berated like that.
20 MR. GOLDBERGER: Actually, we're very happy
21 with the answer.
22 MR. LEOPOLD: That's great.
23 MR. GOLDBERGER: Do you want us to get into
24 that?
25 MR. TEIN: Ted --
61
1 MR. LEOPOLD: This is really big stuff that
2 you're going through, but that's fine; just ask
3 your question and move on. But do it one time.
4 If you don't understand it, I'll let you follow
5 up, but I'm not going to allow you to ask the same
6 question the time and again and then call her a
7 liar. Just ask the question, get the answer and
8 move to the next subject matter.
9 MR. TEIN: Ted, I'm sitting right across
10 the table from you.
11 MR. LEOPOLD: Yes, sir.
12 MR. TEIN: Please be quiet. Don't yell.
13 MR. LEOPOLD: I will not be quiet.
14 MR. TEIN: Stop yelling.
15 MR. LEOPOLD: Lewis, when I'm yelling
16 you'll know it. I will not --
17 MR. TEIN: My name is not Lewis.
18 MR. LEOPOLD: I thought your first name was
19 Lewis, Mr. Tein.
20 MR. TEIN: You watched me for three days at
21 the evidentiary hearing where you sat in the back
22 of the courtroom. You should know who I am.
Page 52
HOUSE OVERSIGHT 012447
-0929104.TXT
23 MR. LEOPOLD: Well, that's the impression
24 you must have made in the courtroom.
25 I will not be quiet.
62
1 MR. TEIN: That's obnoxious. Stop being
2 obnoxious. It's stupid. Let's go ahead with the
3 questions.
4 MR. LEOPOLD: I will make the record.
5 MR. TEIN: Let's get on with the questions.
6 MR. LEOPOLD: Do you need a break?
7 (Thereupon, a recess was taken.)
8 BY MR. TEIN:
9 Q. Okay. after you told your manager
10 at the everything that was going on
11 and he told you he would help you any way he could, he
12 hid you in the kitchen from the process servers, correct?
13 A. Incorrect.
14 Q. Isn't it true that lying to avoid service
15 is a meaningless lie to you,
16 A. Incorrect.
17 Q. What is your manager's name?
18 A. I have three. Would you like to know
19 all
20 Q. Who's the one who lied for you?
21 A. Justin.
22 Q. And what did Justin do to lie for you?
23 A. Said I wasn't there.
24 Q. And who did he tell wasn't there?
25 A. Ask him.
Page 53
HOUSE OVERSIGHT 012448
-0929104.TXT
63
1 Q. Where were you when Justin told this
2 someone that you were not at the
3 A. Eating nachos.
4 Q. At the
5 A. Yes.
6 Q. What did you do so that Justin would lie to
7 the process servers for you?
8 A. Nothing.
9 Q. You just got him to lie for you, didn't
10 you?
11 A. No. I had no influence on him saying I
12 wasn't there.
13 Q. He took that upon himself?
14 Isn't it true that Mr. Epstein's process
15 servers had to ask the police to get you out of the
16 restaurant so that they could serve you?
17 MR. LEOPOLD: Objection. Lack of
18 foundation, predicate.
19 BY MR. TEIN:
20 Q. You can answer the question.
21 MR. LEOPOLD: If you know. Don't guess.
22 THE WITNESS: No. Can you repeat the
23 question?
24 MR. TEIN: Don't coach.
25 MR. LEOPOLD: Don't guess.
64
1 MR. TEIN: That's a coaching.
2 MR. LEOPOLD: No. That's an instruction to
3 the client.
4 MR. TEIN: No. You don't do that.
Page 54
HOUSE OVERSIGHT 012449
-0929104.TXT
5 THE WITNESS: Can you repeat the question?
6 MR. LEOPOLD: Let me just state for the
7 record --
8 BY MR. TEIN:
9 Q. Once the police -- isn't it true that
10 Mr. Epstein's process serves had to ask the police to get
11 you out of the restaurant so that they could serve you?
12 A. Incorrect. My boss called the police.
13 Q. And once the police showed up, to stop you
14 from lying to avoid service, you made up another lie that
15 the process servers had harassed you. Isn't that
16 correct?
17 A. Incorrect.
18 Q. You lie all the time, don't you?
19 MR. LEOPOLD: Objection.
20 THE WITNESS: Incorrect.
21 BY MR. TEIN:
22 Q. You have a MySpace page, don't you?
23 A. No longer do I have a MySpace page. I
24 deleted it.
25 Q. When did you delete your MySpace page?
65
1 A. A couple days ago.
2 Q. Who told you to take your MySpace page down
3 a couple of days ago?
4 A. Nobody. I'm sick and tired of MySpace.
5 Q. You all of a sudden got sick and tired of
6 MySpace and just a few days before this deposition you
7 decided to delete your MySpace page, correct?
8 A. Correct.
Page 55
HOUSE OVERSIGHT 012450
-0929104.TXT
9 Q. Is that your testimony under oath?
10 A. Yes.
11 Q. Did you take your MySpace page down because
12 you thought the government might subpoena it?
13 A. Incorrect.
14 Q. Hadn't your MySpace page been up for over
15 three months before you took it down?
16 A. Correct. But I also had made tons of
17 MySpaces over the last years. I just get tired of them
18 and delete them because drama and make new ones.
19 Q. We're going to talk about that.
20 So you deleted your MySpace page after you
21 were already under subpoena for this deposition, correct?
22 A. Correct.
23 Q. What about the MySpace page didn't you want
24 us to see,M
25 A. Nothing.
66
1 Q. Well, we're going to come back to MySpace
2 in a second.
3 A. You do that.
4 Q. I'm going to ask you some questions
5 about why you lie about your age so often, okay?
6 MR. LEOPOLD: Objection to the form.
7 Argumentative.
8 BY MR. TEIN:
9 Q. You lie about your age all the time, don't
10 you?
11 MR. LEOPOLD: Objection, argumentative.
12 THE WITNESS: Incorrect.
13 BY MR. TEIN:
Page 56
HOUSE OVERSIGHT 012451
-0929104.TXT
14 Q. You lie about your age to get body
15 piercings, don't you?
16 A. Incorrect.
17 Q. You have body piercings, don't you?
18 A. Yes.
19 Q. You have four body piercings; isn't that
20 right?
21 A. Five.
22 Q. Other than the pierceings on your ears --
23 I'm not talking about that --
24 A. Oh, then no; just one.
25 Q. And where is the one body piercing?
67
1 A. Belly.
2 Q. When did you get that?
3 A. For my birthday, with my stepmother and my
4 father.
5 Q. And when was that?
6 A. When I was 14.
7 Q. Okay. So you had that body piercing when
8 you met Epstein, correct?
9 A. It might have been, or maybe that -- yeah,
10 either my 14th birthday or my 15th. I honestly don't
11 remember.
12 Q. Now you've lied about your age to get into
13 bars by using driver's licenses that aren't yours,
14 correct?
15 A. Incorrect.
16 Q. Are you swearing under oath that you've
17 never done that?
Page 57
HOUSE OVERSIGHT 012452
-0929104.TXT
18 A. Yes, I swear under oath.
19 Q. And you've lied about your age to buy beer,
20 correct?
21 A. Incorrect.
22 Q. You're swearing under oath that you've
23 never lied to stores about your age?
24 A. I've never lied to a store about my age or
25 anything.
68
1 Q.
2 don't you?
3
4
5
6
7 Q.
8 one.
9
10
11 BY MR. TEIN:
12
13
14
15
16
17
18 BY MR. TEIN:
19 Q.
20
21
22
You try to look much older than you are,
A. Incorrect.
Q. And you've lied about your age on your
MySpace pages, don't you?
A. Incorrect.
All right. Let's look at Exhibit 26-01
MS. BELOHLAVEK: 26-001?
MR. TEIN: Yes.
n t You?
0 I i ed- to everyone I, 4t400
Q. Let's go to Exhibit 33.
MS. BELOHLAVEK: That's 33-001?
TEIN: Correct.
On this page you lied to everyone that you
were 19, didn't you?
A. Incorrect.
MR. LEOPOLD: Just answer the question.
Page 58
HOUSE OVERSIGHT 012453
-0929104.TXT
23 THE WITNESS: Oh, incorrect.
24 BY MR. TEIN:
25 Q. Now you can explain your answer.
69
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24 18?
25
A. I know that I have seen all of these and I
know that this one is mine.
Can you go down?
MR. LEOPOLD: Just for the record, you're
pointing to the photo.
THE WITNESS: I'm pointing to --
BY MR. TEIN:
1§0mgootholgig VOW
gOalt ORTORM
)W: ggEPRP
Q. That's yours, right?
A. Correct. That's mine from a couple years
ago that I have not been on base I don't use that.
Please keep going down, please. And I think that's it,
because there's no one --just that one is mine.
Q. 4.0C
6COOMUTL-
Ot.00401V
A.
V.OttOldt.
yours, correct?
NOW. AY§i
Q. And when you wrote 18 as your age on your
MySpace page, that was a lie, wouldn't it?
A. Correct.
Q. Did you lie about your MySpace page back
then because you couldn't post on MySpace unless you were
A. Correct. There was a rule many years ago
Page 59
HOUSE OVERSIGHT 012454
-0929104.TXT
70
1 that you had to be 18 to have a MySpace.
2 Q. So you lied about your age so you could
3 post on MySpace, right?
4 A. Yes.
5 Q. Let's go back to the top one on this page,
6 33-01.
7
8
Ilotim gth4g0t0t100
AI tôtifJ flow mid
-01:01W-0
XY500g0g0A010110A
4.40AUW$AYW'
' " Ain'. •
IbM0Y00:40iEhhOICK
OMR:
13
14
Lox abbreviation for
it says
POEMODY 'post
':CbttOaCi
Q. Now let's go back to the one that you were
15 pointing to before on this page, where it says your age
16 is 18 and you lied about your age to post MySpace, okay?
17 A. Uh-huh, yes.
18
19
20
Q. All right. Why did you finally put your
true age on your MySpace profile four days before you
morems0400010M ,:-.AtIfYg15.0ZOW
21 A. jAbn khOWOOWS0 taTROWoboorz,
22 MR. LEOPOLD: If you don't understand, ask
23 him to ask the question again.
24 MR. TEIN: Don't coach.
25 THE WITNESS: I don't know which MySpace
71
1 you're talking about.
2 BY MR. TEIN:
3 Q. The MySpace page that you're just pointing
4 to, where it says you were 18.
Page 60
HOUSE OVERSIGHT 012455
-0929104.TXT
5 A. Yes.
6 Q. AmtmtgAor
7
8 Q.
9
10
11
12
13
14
15
16
17 to.
18
19
20
21
22
23
24
25 ever
bouTY0arovunglItZ
Why did you finally post your true age on
your MySpace profile --
A. Uh --
Q. -- four days before you were scheduled to
testify before the Grand Jury?
A. I honestly don't know which MySpace,
because I've had like a bazillion MySpaces and in that
year, I had two, that one and another one and that one's
been deleted. So I don't know which one you're referring
NdfiNtbffidffibdtgthWyMailft—dw WW§d&dit
Your MySpace Page
"'• oorAtuoi
1500.
0040001 NVITAW 1W 040nloty?:
A. No.
Q. You don't remember that.
A. No.
Q. Do you remember Detective Recarey? Did you
meet a Detective Recarey?
72
1 A. I don't know the names.
2 Q. How many different detectives have you met
3 with on this case from Palm Beach?
4 A. Probably a good six or seven, maybe.
5 Q. Did one of the detectives tell you before
6 you testified in the Grand Jury that you should take your
7 MySpace age and put your true age?
8 A. No.
Page 61
HOUSE OVERSIGHT 012456
-0929104.TXT
9 Q. Didn't Detective Recarey have to come to
10 your house to pick you up to get you to testify in front
11 of the Grand Jury?
12 A. Possibly, maybe because I didn't have a
13 ride. I was only 14 or 15 at the time.
14 Q. Your mom didn't drive you?
15 A. No.
16 Q. Stepmom didn't drive you?
17 A. I think my dad. Oh, my dad / my dad drove
18 me.
19 Q. Your dad drove you?
20 A. Yes, sir.
21 Q. So your testimony is Detective Recarey did
22 not drive you, correct?
23 MR. LEOPOLD: Objection /asked and
24 answered.
25 THE WITNESS: No. I'm pretty sure my dad
73
1 drove me because he was there with me.
2 BY MR. TE1N:
3 Q. Did any detective tell you to change your
4 age on your MySpace page to put your true age?
5
6
7
8
9
12
13
A. No, sir.
Q. Now you also lied on your MySpace page
about your income, didn't you?
A. Yes.
And..yoti lied, sayir that104410000
APOtt0t0034 -m0104M
Q.
A. Yes.
That was a lie, wasn't it?
Page 62
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-0929104.TXT
14
15
16
youa:lo Hod on your MSpace page
impopv ..Vitor&MOVVIAd dfdtgt4b0Z
17 Ottta:
18
19
20
21 tape-recorded statement that you gave to Detective
22 Michelle Pagan three years ago, didn't you?
23 A. To my knowledge, no, I did not.
24 Q. Well, you lied to the police when you
25 accused Mr. Epstein of attempting to murder your father,
And thatmight hve1eenag
Q.
A.
Q.
Now you also lie to the police, don't you?
No.
Well, you lied to the police in your
74
1 didn't you?
2 A. No. I never heard a statement saying that
3 Mr. Epstein tried to murder my father.
4 Q. You made that statement, didn't you?
5 MR. LEOPOLD: Do you have a statement to
6 show her? That's been asked and answered.
7 MR. TEIN: I'm sorry. I didn't hear the
8 witness' answer, Mr. Leopold.
9 BY MR. TEIN:
10 Q. you told the police, didn't you,
11 that Mr. Epstein almost killed your father, didn't you?
12 A. No.
13 Q. Three years ago, before Mr. Epstein even
14 knew about this investigation, you told the police that
15 Epstein had "already come to my dad's house and did
16 something to my dad's tires and my dad almost died. 1
17 didn't want my dad to get hurt, because Jeff already
Page 63
HOUSE OVERSIGHT 012458
-0929104.TXT
18 almost killed him."
19 Didn't you say that?
20 A. Not to my knowledge or recollection. I
21 have never said anything like that.
22 4tg 144WWWWWWDOOONCOMMOW .
23 Joo t vo.moie
24 A. Yeah.
25 Q. Because Mr. Epstein never came to your
75
1 dad's house, correct?
2 A. Correct.
3 Q. And no one who worked for Mr. Epstein ever
4 did something to your dad's tires. Did they?
5 MR. LEOPOLD: Objection. Lack of
6 foundation, predicate.
7 Don't guess.
8 BY MR. TEIN:
9 Q. Its not true that Mr. Epstein almost
10 killed your father, is it?
11 MR. LEOPOLD: Objection. Asked and
12 answered, lack of foundation, predicate.
13 BY MR. TEIN:
14 Q. You can answer.
15 A. No.
16 Q. Now you told the police that you didn't
17 know who was in the car with you and Hayley on the day
18 you went to Epstein's house, didn't you?
19 A. Yes.
20 Q. And that was a lie, wasn't it?
21 A. It's the truth.
22 Q. You told the police that there was someone
Page 64
HOUSE OVERSIGHT 012459
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23 in the car next to you and you specifically said you
24 didn't know her name, right?
25 A. Correct. I do not know her name.
76
Q. You said, "I don't know her name, but she
2 was dark like a Spanish girl." Those were your words,
3 right?
4 A. Yes.
5 MR. LEOPOLD: Objection. Asked and
6 answered.
7 BY MR. TEIN:
8 Q. Who was in the car that day with you and
9
10 A. Again, I do not know.
11 Q. It was your good friend
12 wasn't it?
13 A. No. I don't know a
14 Q. You lied to the police about who was in the
15 car with you and , didn't you?
16 A. Incorrect.
17 Q. Let me ask you some questions about who you
18 may have spoken to about this case. All right?
19 A. Go ahead.
20 Q. Did you speak to your sister.=
21 A. Not in detail, but of course she knows;
22 she's family and yes.
23 Q. What's her e-mail?
24 A. I don't think she has an e-mail.
25 Q. What is her phone number?
Page 65
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-0929104.TXT
77
1 A. Oh, gosh. I don't know off the top of my
2 head.
3 Q. And what is her home address?
4 A. She lives with my mom.
5 Q. In Georgia?
6 A. Yes, sir.
7 Q. What about 's boy friend Paul? Did
8 you speak to him about Epstein's case?
9 A. That's my mom's boy friend. My sister
10 doesn't have a boy friend. My mom's husband's name is
11 Paul, so maybe you get them confused.
12 Q. Do you know his phone number?
13 A. No.
14 Q. Where does he live?
15 A. With my mom.
16 Q. In the same house with her?
17 A. Yes. They're married.
18 Q. So not boy friend; husband?
19 A. Yeah, husband.
20 Q. Have you spoken to Brett about
21 what happened in Mr. Epstein's house?
22 A. Not in detail, but he knows the basics,
23 yes.
24 Q. What is his e-mail?
25 A. I don't know.
78
1
2
3
4
Q. What is his phone number?
A. How is that relevant?
Q. What is his phone number?
A.
Page 66
HOUSE OVERSIGHT 012461
-0929104.TXT
5 Q. What is his home address?
6 A. I don't know.
7 Q. Where does he live?
8 A. In somewhere.
9 Q. Ever been to his house?
10 A. Yes.
11 Q. You don't know what his address is?
12 MR. LEOPOLD: Objection. Asked and
13 answered. She just said she doesn't know.
14 MR. TEIN: Don't coach.
15 MR. LEOPOLD: Objection. Asked and
16 answered.
17 BY MR. TEIN:
18 Q. You can answer the question.
19 A. I don't know the exact address.
20 Q. What street is it on?
21 A. It's an apartment complex; its not a
22 street.
23 Q. What's the name of the apartment complex?
24 A.
25 Q. What apartment number is it?
79
1 A. I couldn't tell you.
2 Q. When was the last time you went there?
3 A. Just visited this past weekend. That's the
4 first and last time I went there.
5 Q. How about Steven M? Have you spoken
6 to him about your case?
7 A. No. We no longer speak.
8 Q. What's his phone number? Actually, we
Page 67
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-0929104.TXT
9 10 11   already have his phone number room and e-mail.   you ever
How about Have
spoken to her about your case?
12   A. I don't know an
13   Q. Have you ever met
14   A. No. But just to I et you know, I don' t
15   really know names. If you have pictures, of there faces
16   I could tell you.
17 18   Q. All right. Let me see if I can refresh your memory.
19   A. Okay.
20   Q. Does it refresh your memory that
21   is the other girl who made allegations about Epstein, but
22 23   refused to show to the Grand Jury when she had to testify about them under oath?
24   A. No, sir. I have no knowledge of any other
25   girls in this whole situation. We're not allowed to know
1   80 each other.
2   Q. I91I4figtA0Wutoa20 four..............................words,
3   A. mommbM4413bWOMt061010WOOW moom
4 5   Q. And what about ? Have you of met her?
6   A. No, sir.
7   Q. Let's see if I can refresh your memory on
8   her. She's the other person represented by your lawyer
9 10   Mr. Herman, who is suing Epstein for fifty million dollars.
11   A. I have no knowledge of her.
12   Q. Never met her?
13   A. Never met her.
Page 68
HOUSE OVERSIGHT 012463
were [eased on the Internet containing You
. . . .. .. .. . . ..
-0929104.TXT
14 Q. MI11111111111
15 A. I don't know who that is either.
16 Q. A person named Anthony who knows
17 Is that Tony
18 A. I don't know, sir.
19 Q. Do you remember making a statement to
20 Detective Pagan that's in the police reports?
21 A. No.
22 Q. Have you read the police reports in this
23 case?
24 A. Yes.
25 Q. They're on the Internet, right?
81
1 A. Yes, I think.
2 Q moroyarsomelo Rohouthomaii0ogre015.t0i
3
4 MbAt ACAORM
5 ...... Y.d
6 Q. You didn't want to see that happen, right?
7 A. No.
8 Q. So you're saying you don't know a Tony
9 IIIIIIIIIk
10 MR. LEOPOLD: Objection. Asked and
11 answered.
12 BY MR. TEIN:
13 Q. Does it refresh your memory that he was
14 somebody who had gone to jail for drugs and car theft?
15 A. No, sir
16 Q. Someone who knowsIIIIIII
17 A. No.
Page 69
r statements
HOUSE OVERSIGHT 012464
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18 Q. You don't know if he met with Detective
19 Recarey?
20 A. No, sir.
21 Q. How about Zack=?
22 A. Yes, I remember. I know who that is.
23 Q. Did you ever speak to Zack about what
24 happened at Mr. Epstein's house?
25 A. He knows what happened four years ago. He
82
1 doesn't know this is still going on today.
2 Q. What's his address? I'm sorry. I have his
3 address.
4 A. I don't know.
5 Q. How about Nick
6 A.
7 Q. You know who that is?
8 A. I know who that is, yes.
9 Q. He's the one you stayed out drinking all
10 night one night last year when your dad reported you
11 missing?
12 A. No, sir.
13 Q. Remember the baseball game you were
14 supposed to go to?
15 A. No, sir.
16 Q. Did you speak to Nick about this
17 case?
18 A. No, sir.
19 Q. How about Patrick
20 A. That's my sister's ex-boy friend.
21 Q. He's the one with the sawed-off shotgun
22 with the obliterated serial number?
Page 70
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23 A. Ask him. I would not know that
24 information.
25 Q. Did you speak to Patrick about this
83
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
case?
A. No, sir.
Q. Have you spoken to John about this
case?
A. No. I don't know who John is.
Q. Did your parents speak to John?
A. Ask my parents.
Q. Let's see if I can refresh your memory as
to who he is. Okay?
A. Uh-huh.
MOAWm;  \iarity Fr reporter OWItigd60:
txParmi0jagetWOOMOM. ..... OtENOW
iiir.10)0§Orki;i0FiVIIMAR *.g!tiOt
ails a 0
ke that they
what ou know
MilOWKWWW110
100
000ttfliki
OPPAllgOMOO.Vt[44:
iii Conr
porter
father
don't know out thedi
Q.
your father?
A. I don't even know he gave money to my dad.
Q. I'm sorry?
A. I didn't even know he gave money to my dad.
ail
How much money did John Connolly give to
Page 71
HOUSE OVERSIGHT 012466
-0929104.TXT
84
1 Q. What do you know about the deal that John
2 Connolly has with your father?
3 A. I only know they spoke on the telephone
4 once. I don't know anything else.
5 Q. When was that?
6 A. This was a while ago, a year or two or a
7 year ago. I honestly don't know.
8 Q. Did John Connolly the Vanity Fair reporter
9 offer any money to your father?
10 A. I don't know.
11 Q. Did John Connolly, the Vanity Fair
12 reporter, give you any money?
13 A. No, sir.
14 Q. Did he offer you any money?
15 A. No, sir. Never spoke to him.
16 Q. What reporters have you spoken to?
17 A. Zero.
18 Q. What about your family members? What
19 reporters have they spoken to?
20 A. The whole Palm Beach County, obviously, as
21 you can see in that newspaper.
22 Q. Tell me -- let's go through each one that
23 you remember. Other than the Vanity Fair reporter, John
24 Connolly, what other reporters have any member of your
25 family spoken to?
85
1 A. I don't know. And I know my mom has spoken
2 to zero. My sister spoke to zero. My father and
3 stepmother, I wouldn't know. You'd have to ask them.
4 don't contact them.
Page 72
HOUSE OVERSIGHT 012467
-0929104.TXT
5 Q. Well, I just want to know -- I don't want
6 you to -- I want to know what's in your mind? All right?
7 MR. LEOPOLD: She just told you. She just
8 answered --
9 MR. TEIN: Be quiet.
10 BY MR. TEIN:
11 Q. What I want to know is what you know from
12 your personal knowledge. My opinion question to you is:
13 What knowledge do you have about family members of yours
14 speaking to reporters?
15 MR. LEOPOLD: Objection. Asked and
16 answered.
17 And if you can't talk professionally, we're
18 going to leave.
19 MR. TEIN: Do what you want to do.
20 MR. LEOPOLD: Are you going to continue to
21 talk this way?
22 MR. TEIN: I'm not going to answer any
23 question that you ask me, Mr. Leopold.
24 MR. LEOPOLD: Okay.
25 MR. TEIN: But you are misrepresenting the
86
1 record and you are grandstanding for your client
2 and it's wrong. So be quiet. And you know how to
3 make an objection. Make it. Otherwise stop
4 talking.
5 BY MR. TEIN:
6 Q. Saige --
7 MR. LEOPOLD: Excuse me.
8 MR TEIN: If you want to leave the
Page 73
HOUSE OVERSIGHT 012468
-0929104.TXT
9 deposition, leave. But you'll be back here.
10 MR. LEOPOLD: Excuse me. If I could just
11 make the record, instead of interrupting me,
12 please, that's what we do professionally. There's
13 a recorder here. I'm certainly not being
14 obstructionist. I'm going to make the record.
15 But were going to act with some semblance of
16 professionalism, hopefully, by all parties in the
17 room. That goes to me, that goes to your
18 co-counsel sitting behind you and next to you, the
19 court reporter and everyone else in the room.
20 Everyone goes entitled to that.
21 You've asked a question. She answered the
22 question fully and she's not going to be harassed
23 because you don't like the answer. If you want to
24 follow up --
25 MR. TEIN: Stop engaging me. Make your
87
1 speech and then we'll ask the questions.
2 MR. LEOPOLD: Well, you won't let me finish
3 making the objection, so it's difficult to do
4 that. But if you want to follow with an
5 appropriate question, feel free to do that. But
6 we're not going to harass the witness.
7 MR. TEIN: I disagree with everything
8 you've said. Let's ask the questions. Okay?
9 MR. LEOPOLD: Ask an appropriate question
10 MR. TEIN: Are you going to stop talking?
11 MR. LEOPOLD: I'm going to make -- protect
12 my client and make appropriate objection, but
13 there's not a question pending right now.
Page 74
HOUSE OVERSIGHT 012469
-0929104.TXT
14 BY MR. TEIN:
15 Q. has spoken to any reporters?
16 A. No.
17 MR. LEOPOLD: Objection. Asked and
18 answered.
19 BY MR. TEIN:
20 Q. Has been given money by any
21 reporters?
22 A. No.
23 Q. Has your mom spoken to any reporters?
24 MR. LEOPOLD: Objection. Asked and
25 answered.
88
1 THE WITNESS: No.
2 BY MR. TEIN:
3 Q. Has your mom's husband Paul spoken to any
4 reporters?
5 A. No.
6 Q. Has your mom's husband Paul received any
7 money from reporters?
8 A. No.
9 Q. Are you sure you don't know
10 MR. LEOPOLD: Objection. Asked and
11 answered.
12 THE WITNESS: I'm positive.
13 BY MR. TEIN:
14 Q. I'll try again to refresh your memory.
15 A. Okay.
16 Q. Does it refresh your memory that she had
17 been arrested for drugs and was cooperating with
Page 75
HOUSE OVERSIGHT 012470
-0929104.TXT
18 Detective Recarey against Epstein to get herself a better
19 deal?
20 A. No. I don't know who she is.
21 Q. Have you spoken to anyone else who's been
22 at Epstein's house?
23 A. No.
24 Q. Without telling me what was said -- I don't
25 want to know about any conversations with any lawyers,
89
1 okay --
2 A. Uh-huh.
3 Q. -- did you or your parents speak to any
4 other law firms besides Mr. Herman and Mr. Leopold's law
5 firms?
6 A. No.
7 Q. Now without telling me about anything that
8 was said, what -- did one just come to mind?
9 A. No. I was thinking about something else.
10 Q. What were you thinking about?
11 A. Does family court matter?
12 Q. Okay. Without telling me what was said,
13 who prepared you for todays deposition?
14 A. What do you mean prepared?
15 Q. Did you talk about this deposition, about
16 what would happen, with anybody?
17 A. Yes.
18 Q. Don't tell me what was said?
19 A. Okay.
20 Q. I'm not asking that. I don't want to know
21 that.
22 A. Okay.
Page 76
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23 24 25 1 2   Q. A. Q. A. Q.   Who prepared you for today's deposition? Mr. Leopold. Anybody else? 90 No. When did you meet with Mr. Leopold to
3   prepare for today's deposition?
4   A.   This morning.
5   Q.   And how long did that meeting last?
6   A.   Until it started.
7   Q.   Now you told me that you previously had
8   read the police reports in this case?
9   A.   Yes.
10   Q.   Have you read your statement that you gave
11   to the police?
12   A.   Yes, sir.
13   Q.   And in what form was that statement?
14   A.   What do you mean?
15   Q.   Was it in the form of a police report or a
16   transcript?
17   A.   What's the difference?
18   Q.   A transcript has questions and answers on
19   it. A police report is just typed out narrative.
20   A.   Oh, its a police report.
21   Q.   And when did you read the police report?
22   A.   A few days ago. I overread it a few days
23   ago.
24   Q.   Had you read it before that?
25   A.   No.
Page 77
HOUSE OVERSIGHT 012472
-0929104.TXT
91
1 Q. Now you told me -- again, I don't want to
2 know what was said.
3 A. Uh-huh.
4 Q. You told me that you met with Mr. Leopold
5 this morning to prepare for your deposition, right?
6 A. Yes.
7 Q. When did you set up that meeting with
8 Mr. Leopold to take place this morning?
9 A. Gee, like, like five days ago, four days
10 ago.
11 Q. So you're aware that Mr. Leopold told us
12 that he could not start the deposition this morning
13 because he had a court appearance, correct?
14 MR. LEOPOLD: Don't answer that question.
15 Calls for attorney/client communications.
16 BY MR. TEIN:
17 Q. Have you seen the letter that Mr. Leopold
18 wrote to us stating that he -- an e-mail that Mr. Leopold
19 wrote to Mr. Goldberger stating that he could not be here
20 this morning because healed a court appearance? Did you
21 see that e-mail?
22 MR. LEOPOLD: You can answer that question.
23 THE WITNESS: No.
24 BY MR. TEIN:
25 Q. Have you listened to your tape-recorded
92
1 statement to the police?
2 A. Yes.
3 Q. Where did you listen to that?
4 A. In, I think, this building. I don't know.
Page 78
HOUSE OVERSIGHT 012473
-0929104.TXT
5 It was here.
6 Q. When did you listen to that statement?
7 A. This morning.
8 Q. And who was present when you listened to
9 that statement?
10 A. Mr. Leopold -- and I forget your name.
11 MR. GOLDBERGER: Ms. Belohlavek.
12 THE WITNESS: Ms. Belohlavek.
13 BY MR. TEIN:
14 Q. And you hadn't listened to your statement
15 before that, correct?
16 A. No, sir.
17 Q. Have you met with lawyers representing
18 anyone else suing Epstein?
19
20
21
22
23 tW*404_ft_fddt4dAMVWALTAit —taTtidtH
A. No, sir.
Q. How -many times have you tOgOttIOOPO
'he Palm Beach
partment?
More
KH„,,,ztafhtM
A.
24 Q. When was the last time you spoke with
25 officers of the Palm Beach Police Department?
1 A. A while ago. I'd say a year ago.
2 Q. A year ago?
3 A. Yeah. Maybe a year and a half.
4 Q. Do you remember Detective Recarey?
5 A. No.
6 Q. Do you remember Michelle Pagan, Detective
7 Pagan?
8 A. Yes.
Page 79
93
HOUSE OVERSIGHT 012474
Appgmorammolgprommomono :9PORaft -'TtlatZ
-0929104.TXT
9 Q. How many times have you spoken to Detective
10 Pagan?
11 A. She was the only one I spoke to about this
12 until for some reason she wasn't on the case anymore.
13
Q. When was that?
14 A. The first meeting I ever had was with her
15 and then I think like I met with her mgolp opow 0.2tz
16 MMO% d$OMOttar CO4t0OW 000, XOWTEV
17
18 Q. And who was that?
19 A. I don't remember.
20 Q. And what type of questions did they ask
21 you?
22 A. The same.
23 Q. The same questions all over again?
24 A. Basically.
25 Q. How many taped statements have you given to
94
1 the police?
2 A. One that I know of.
3 Q. Just the one with Detective Pagan?
4 A. Yes, sir.
5 Q. How about to the FBI? Did you give any
6 statements to them?
7 A. No. Well, actually. I don't really
8 remember if that was taped or not to be honest with you.
9 I had one meeting with them at my house and don't know if
10 it was taped.
11 Q. You were interviewed at
12 house?
13 A. No. That was by the lawyer.
Page 80
HOUSE OVERSIGHT 012475
-0929104.TXT
14 Q. Oh, boy the lawyer?
15 A. Uh-huh.
16 Q. Where did the conversation that you had
17 with the FBI take place?
18 A. At my father's residence.
19 Q. Which is where?
20 A. On Downers in Loxahatchee.
21 Q. On where?
22 A. Downers Road in Loxahatchee.
23 Q. And when did that take place?
24 A. I'd have to say like a year and a half ago,
25 a year ago. It was a long time ago.
95
1 (Discussion held off the record.)
2 MR. TEIN: Tell me the last answer, please.
3 (Thereupon, a portion of the record was read
4 by the reporter.)
5 BY MR. TEIN:
6 Q. And who was present when the FBI spoke to
7 you at your father's house?
8 A. My stepmother was there, but she wasn't
9 around. She made herself like do other things.
10 Q. And how many FBI agents were there?
11 A. I think four.
12 Q. And you don't remember any of their names?
13 A. No, sir.
14 Q. And were there any lawyers there?
15 A. Not that I know of.
16 Q. And none of them gave you their cell phone
17 numbers?
Page 81
HOUSE OVERSIGHT 012476
-0929104.TXT
18
19
20
21
22
23
24
25
A. No.
0. Anomigmou
90.40
ONOW1408A
go?
A. It was a while ago.
MR. LEOPOLD: Objection. Asked and
answered.
BY MR. TEIN:
Q. And the last time you spoke to the federal
96
1 prosecutor's office was when?
2 A. I don't know.
3 Q. Did any of the FBI agents tell you that
4 Marie Villafona had spoken with Mr. Leopold?
5 A. No.
6 Q. Did any of the FBI agents tell you that
7 Marie Villafona had spoken with Mr. Herman?
8 A. No.
9 Q. Did any FBI agents tell you that Jeff
10 Sloman spoke with Mr. Herman.
11 A. No.
12 Q. Did any FBI agents tell you that Jeff
13 Sloman spoke with Mr. Leopold?
14 A. No.
15 Q. Do you know whether any of the federal
16 prosecutors allowed Mr. Herman to review a draft
17 indictment?
18 A. I wouldn't know.
19 Q. Do you know if any of the federal
20 prosecutors discussed a draft indictment with Mr. Herman?
21 A. I wouldn't know.
22 Q. Have you ever e-mailed with any FBI agent
Page 82
HOUSE OVERSIGHT 012477
-0929104.TXT
23 or any federal prosecutor?
24 A. No.
25 Q. Have you ever text messaged with any FBI
97
1 agent or any federal prosecutor?
2 A. No
3 Q. Has the FBI told you about other testimony?
4 A. No.
5 Q. Has the FBI told you about what other girls
6 have said?
7 A. No.
8 Q. Have federal prosecutors told you what
9 other girls have said?
10 A. No.
11 Q. Do you have any way of getting in touch
12 with the FBI if you wanted to get in touch with them?
13 A. No.
14 Q. How about your parents? Do they know how
15 to get in touch with the FBI?
16 A. I don't know.
17 Q. And by your parents, I'm referring to both
18 sets, okay?
19 A. Oh. Well, I'm referring to only my dad,
20 because my mom really doesn't care to know any of this
21 stuff.
22 Q. So the answer would be the same for your
23 mom and Paul?
24 A. Yeah. -
25 Q. Have you spoken to a lawyer named Burt
Page 83
HOUSE OVERSIGHT 012478
-0929104.TXT
98
1 Ocariz about this case?
2 A. No.
3 Q. Do you know who Burt Ocariz is?
4 Let's see if I can refresh your memory.
5 Does it refresh your memory that he's a good friend of
6 Marie Villafona's boyfriend?
7 A. I don't know who Mari Villafona is.
8 Q. Marie Villafona is the lead federal
9 prosecutor that's on the federal part of this case.
10 Okay?
11 A. No.
12 Q. So does it refresh your memory that Ocariz
13 is the good friend of Marie Villafona's boy friend?
14 A. Not at all.
15 Q. Does it refresh your memory that Villafona
16 tried to get Epstein to pay for Ocariz to represent you
17 in the federal case?
18 A. No.
19 Q. Do you know if Detective Recarey has spoken
20 with your father?
21 A. No.
22 Q. Do you know if Detective Recarey has spoken
23 to your stepmother?
24 A. No.
25 Q. How about with amber?
99
1 A. Yes, I would know, and no, she did not.
2 Q. Let's put up -- let me ask you some
3 questions about the photo that you had posted on your
4 MySpace page before you erased it last week. Okay?
Page 84
HOUSE OVERSIGHT 012479
-0929104.TXT
5
6
7
8
9
10
11
12
13
14
15
16 BY MR. TEIN:
17
18
19
20
21
22
23
24
25
1
2
3
A. Okay.
MR. TEIN: Do you mind if we close the door
a second, please.
MR. LEOPOLD: Exhibit number, please.
MR. TEIN: Put up 25-005.
Hold on a second.
MR. LEOPOLD: Don't say anything. She was
talking to her counsel.
MR. TEIN: Put up 25-006.
MR. LEOPOLD: Is that 005 right there?
MR. TEIN: Yes.
toOkl
photo
ou h a warehouse
y.,!:;;;ogtoitfa.
MR. LEOPOLD: Objection. Mischaracterizes
the photograph, and lack of foundation and
predicate.
Fully explain if you need to.
THE WITNESS: I will.
First of all. Oft 2004A1W0P000$0.Z
t6V6W IglgOP4W:
Second of all, I'm not being gang-raped.
Everyone has their clothing on.
Thirdly, if you look at all the other
100
4 pictures in this album, I'm drinking -- what's
5 when you're sick you drink it?
6 BY MR. TEIN:
7 Q. You can't ask questions of your counsel.
8 A. All right. I'm drinking like Sprite. I'm
Page 85
HOUSE OVERSIGHT 012480
-0929104.TXT
9 note drinking any kind of alcohol, if you would look at
10 my other pictures in that album. You guys picked the
11 possibly worst pictures out of there to present. And it
12 was just a goofy picture. All of these kids like to be
13 goofy. And that's what we were doing.
14 Q. Who's the man on the left of the picture
15 holding his -- holding a beer bottle as if it were a
16 penis towards your mouth?
17 A. Steven
18 Q. Who's the man behind you, right up towards
19 your backs side, with you bent over?
20 A. That one?
21 Q. The right side, kissing with his mouth.
22 A. That's Nick
23 Q. He's the one grabbing towards the groin
24 area of Steven
25 A. Yes.
101
1 Q. And there's three other men in the photo.
2 What are their names? The one on the left with the hat?
3 A. That's Robbie (phonetic).
4 Q. Smiling?
5 A. Yes.
6 Q. Who's the one kissing --
7 MR. LEOPOLD: Don't interrupt. Let her
8 finish the record. She's testifying.
9 MR. TEIN: I know you don't like this
10 picture, my friend.
11 MR. LEOPOLD: The picture is fine.
12 BY MR. TEIN:
13 Q. Who's the one with the hat?
Page 86
HOUSE OVERSIGHT 012481
-0929104.TXT
14 MR. LEOPOLD: No. Hold on. Stop,
15 You have to let the witness finish her
16
17
18
19
20
21
22
23
24
25 BY MR. TEIN:
1 Q. He's the one whose head is near the groin
2 of Steven , right?
3 A. Yes.
4 Q. And in the middle there's a man smiling.
5 Who's that?
6 A. That's Robbie
7 Q. Who's the one in the red hat, kissing?
8 A. Most Brandon (phonetic).
9 Q. Let me stop you for a second. Are you
10 done?
11 A. Yes, I'm done.
12 Q. Who is
13 A. My sister's friend. Well, she's a mutual
14 friend, but more my sister's.
15 Q. What is her last name?
16 A.
17 Q. Spell that.
Page 87
answer. She was in the process of explaining and
you cut her off.
Please finish what you were saying and then
Counsel can ask you whatever he wishes after that.
THE WITNESS: Okay. This guy --
MR. LEOPOLD: Just make it so the record is
clear who you're referring to.
THE WITNESS: -- on the far left is John
102
HOUSE OVERSIGHT 012482
-0929104.TXT
18 A. I don't know how to --
19 Q. Have you spoken to her about this case?
20 A. No.
21 Q. Who's Vince?
22 A. My sister's friend. I don't really speak
23 to him at all.
24 Q. What's his last name?
25 A.
103
1 Q.
2 A.
3
4 case?
5
6
Q. And have you spoken to Vince about this
A. No, sir.
Q. Have you spoken to about this case?
7 A. Not in detail, but yes.
8 MS. BELOHLAVEK: Are we referring to
9
10 THE WITNESS: Yes.
11 MR. TEIN: Yes.
12 MS. BELOHLAVEK: Okay.
13 BY MR. TEIN:
14 Q. Have you spoken to Justin about this case?
15 A. Justin?
16 Q. Do you have a friend named Justin?
17 A. I do not have a friend named Justin.
18 Q. From freshman year?
19 A. No.
20 Q. How about In
21 A. No.
22 Q. Have you spoken to 1111 about this case?
Page 88
HOUSE OVERSIGHT 012483
-0929104.TXT
23 24 25   A. Q. A.   No. What's her last name? . I don't know how to spell it?
104
1   Q.   Is she the person whose house you went to
2   on New Year's this year?
3   A.   No. I wasn't at her house on New Year's.
4   Q.   Where were you when you took the picture of
5   Can you say blazed? That on your website?
6   A.   I wouldn't know or -- wait. We were at a
7   birthday party for some girl's 16th birthday.
8   Q.   Were you drinking at that party?
9   A.   No. There was no alcohol or anything
10   there.
11   Q.   What does "blaze" mean to you?
12   A.   It's like -- it just means like messed up.
13   But we weren't, if you look at the picture.
14   Q.   Messed up like drunk, right?
15   A.   Sure.
16   Q.   Who's
17   A.   A girl I know like from like two years ago.
18   Q.   She's the one you were supposed to be
19   staying with when you went drinking with Nick
20   A.   No.
21   Q.   What's 's last name?
22   A.
23   Q.   Where does she live?
24   A.   I don't know. In Royal Palm.
25   Q.
Page 89
HOUSE OVERSIGHT 012484
-0929104.TXT
105
1 A. Uh-huh. I'm guessing.
2 Q. Do you know her phone number?
3 A. No, I do not.
4 Q. Let's look at 25-010.
5 A. See, tin drinking --
6 Q. I'm not asking you about what you're
7 drinking.
8 Who are the men in this photo who are
9 pretending to gang up on you and stab you with knives?
10 Who are they?
11 A. Nick and Brandon (phonetic).
12 Q. Are they firemen?
13 A. Are those? Steven -- he said the
14 two stabbing with knives. That's why I said that. 1
15 don't know. That's Steven and John
16 Q. Are these firemen?
17 A. No. They're all on -- except Steven,
18 they're all on full rights for football.
19 Q. Go to 025-015?
20 MR. LEOPOLD: 025- dash?
21 MR. TEIN: 015.
22 THE WITNESS: Gosh, that's so long ago.
23 BY MR. TEIN:
24 Q. Who took the photo have you licking the
25 penis?
106
1 A. My stepmother.
2 Q. Whose idea -- that was your stepmother's
3 idea?
4 A. It was in Buca di Beppo, where she works
Page 90
HOUSE OVERSIGHT 012485
-0929104.TXT
5 currently and that was before she worked there, and we
6 just thought it would be funny.
7 MR. TEIN: 19-007. Can you enlarge that?
8 BY MR. TEIN:
9 Q. Who took this photo of you simulating you
10 having sex with a man?
11 A. We're not simulating having sex, and
12 it's -- oh, and the person who took it was, I'm pretty
13 sure, Chris, but I know him as don't know his
14 last name.
15 Q. Go to 19-006, please.
16 Who took this photo of you simulating sex
17 with a man?
18 A. The same person. And we're not simulating
19 having sex, Mr. --
20 Q. Tein.
21 Did you post that on the Internet?
22 A. Actually, this is an old MySpace I never
23 finished and I never like did anything. I just kind of
24 made it and left it.
25 Q. So the answer is yes, you posted this on
107
1 MySpace?
2 A. Yup.
3 Q. Go to 25-016. Who took this photo of you
4 simulating sex with a woman?
5 MR. LEOPOLD: Object to the form of the
6 question. Argumentative.
7 THE WITNESS: First off, she's piercing my
8 belly button or repiercing it, and I'm pretty sure
Page 91
HOUSE OVERSIGHT 012486
-0929104.TXT
9 it was just like we put up a camera somewhere and
10 put a timer on it. We didn't have anybody take
11 it.
12 BY MR. TEIN:
13 Q. You posted that on your MySpace page?
14 A. Yeah.
15 Q. Go to 25-013. Is that a photo of you?
16 A. Yep.
17 Q. Who's in the photo with you?
18 A. Steven.
19 Q. Steven =?
20 A. Yep.
21 Q. Is this you coming out of the shower?
22 A. Yes.
23 Q. Are you clothed in this picture?
24 A. Yeah. I have a halter dress on.
25 Q. Where is that picture taken?
108
1 A. In Steven's house.
2 Q. Did you post that on the Internet?
3 A. Yes.
4 Q. All right.
5 MR. TEIN: You can take that down.
6 BY MR. TEIN:
7 Q. Now your boy friend is Brett
8 correct?
9 A. Yeah.
10 Q. You lie about your age in order to conceal
11 something about your relationship with Brett
12 isn't that correct?
13 A. No.
Page 92
HOUSE OVERSIGHT 012487
-0929104.TXT
14 Q. Brett's 22 years old, isn't he?
15 A. Yes.
16 Q. And Brett is a firefighter with the Palm
17 Beach Fire Department, right?
18 A. Yup.
19 Q. Does the Palm Beach Fire Department know
20 that your boy friend is dating an underage girl?
21 A. Actually, Mister, it's legal.
22 Q. Well --
23 MR. LEOPOLD: Just answer the question,
24
25 THE WITNESS: Yes.
109
1 BY MR. TEIN:
2 Q. Did they know two weeks ago that you were
3 dating an underage girl (sic)?
4 A. Yes. I met everybody in there.
5 Q. Did they know your age?
6 A. Yes.
7 Q. Did you lie about your age so that the fire
8 department wouldn't think that Brett is committing a
9 crime by having a sexual relationship with an underage
10 girl?
11 MS. BELOHLAVEK: Objection. Assumes facts
12 not in evidence.
13 BY MR. TEIN:
14 Q. You can answer the question.
15 A. No.
16 Q. Does the Palm Beach Police Department know
17 that Brett is having a sexual relationship with an
Page 93
HOUSE OVERSIGHT 012488
-0929104.TXT
18 underage girl?
19 MR. LEOPOLD: Don't guess. Answer if you
20 know.
21 THE WITNESS: Can you repeat the question?
22 BY MR. TEIN:
23
24 thowarom m4ormof
25
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110
1 AZ #000160A0B-
2 Q. You lie about your twin sister don't
3 you?
4 MR. LEOPOLD: Objection. Argumentative.
5 BY MR. TEIN:
6 Q. Don't you?
7 A. No. I have never lied for or to
8 Q. You lie about the fact that she has a s
9 drug habit, right?
10 A. No. I would never accuse my sister of
11 having a drug habit.
12 Q. Do you try to conceal the fact that she has
13 a drug habit?
14 MR. LEOPOLD: Objection. Argumentative.
15 BY MR. TEIN:
16 Q. You can answer the question.
17 A. No. My sister does not have a drug habit.
18 Q. You lied when you-went to the crack house
19 in Georgia, didn't you?
20 MR. LEOPOLD: Objection. Argumentative.
21 Lack of foundation, lack of predicate.
22 THE WITNESS: Never -- what did you say?
Page 94
HOUSE OVERSIGHT 012489
-0929104.TXT
23 BY MR. TEIN:
24 Q. You lied when you went to the crack house
25 in Georgia, didn't you?
111
1 MR. LEOPOLD: Objection. Argumentative.
2 Lack of foundation, lack of predicate.
3 BY MR. TEIN:
4 Q. You can answer the question.
5 A. I have never been to a crack house.
6 Q. Who don't you lie to?
7 MR. LEOPOLD: Objection. Argumentative.
8 Don't answer the question.
9 MR. TEIN: Certify it.
10 ..................CERTIFIED QUESTION..................
11 BY MR. TEIN:
12 Q. You don't lie to , do you?
13 MR. LEOPOLD: Objection. Asked and
14 answered.
15 Don't answer the question.
16 BY MR. TEIN:
17 Q. No. You can answer that question.
18 MR. LEOPOLD: No. I just told her not to.
19 You've asked that question about five --
20 MR. TEIN: No, I haven't.
21 MR. LEOPOLD: Don't answer the question.
22 MR. TEIN: I'll certify it.
23 ..................CERTIFIED QUESTION..................
24 MR. LEOPOLD: For the record, you have to
25 stop interrupting me because she can't take down
Page 95
HOUSE OVERSIGHT 012490
-0929104.TXT
112
1 both of us talking at the same time.
2 BY MR. TEIN:
3 Q. You tell the truth, don't you?
4 A. Excuse me?
5 Q. You tell IIIIIIthe truth, don't you?
6 A. When it's -- yes, I tell the truth.
7 Q. Who's s drug dealer?
8 A. My sister does not have a drug dealer. She
9 lives in Georgia with my mother.
10 Q. Okay- MIVRINEWCWOI0010#EWW640§000
11 you and off at 5:45 a.m. in 2006, after being out
12 all night, the two of you, using drugs at Palm Beach
13 Country Estates where your father called the police?
14 A. VIM=
15 Q. He's the drug dealer?
16 A. He is a drug dealer.
17 Q. Do you remember was arrested by the
18 Palm Beach Police Department and taken to the Juvenile
19 Assessment Center that morning?
20 A. I do remember that.
21 Q. Now before you massaged Epstein, you were
22 involuntarily admitted into a juvenile educational
23 facility; isn't that right?
24 A. Did you say involuntarily.
25 Q. Yes.
113
1 A. No. I was willing to go. I -- duly said
2 sure.
3 Q. And you went there because you were lying
4 so much, no one could control you; isn't that correct?
Page 96
HOUSE OVERSIGHT 012491
7
8
9
-0929104.TXT
5 A. Very incorrect.
6 Q. Now you lie to your parents all the time,
don't you?
A. Incorrect.
MR. LEOPOLD: Objection. Argumentative.
21
22
23 accused you of lying?
24 A. All the time.
Sorry?
Incorrect.
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rcorromo
You admitted to the police that you told
10 BY MR. TEIN:
11 Q.
12 A.
13
16
17
18 your father that you were going shopping, didn't you?
19 A. Yes.
20 SW Alla 004.M
:OOP
Q. And isn't it true that your father has
25 Q. Didn't your father throw you out of the
114
1 house Thanksgiving of this past year because you were
2 lying so much to him?
3 A. Yes, he did kick me out No, that's not
4 the reasons why.
5 Q. Didn't your father throw your sister
6 out of the house, too?
7 A. Yes.
8 Q. And he threw her out of the house the week
Page 97
HOUSE OVERSIGHT 012492
-0929104.TXT
9 after Thanksgivings, right?
10 A. I don't know the date, but sure.
11 Q. Sounds about right?
12 A. Sure.
13 Q. And the reason he threw her out of the
14 house was because she was lying, too?
15 MR. LEOPOLD: Objection. Lack of
16 foundation. Calls for speculation.
17 BY MR. TEIN:
18 Q. When your counsel coaches you, you say it's
19 correct, right?
20 A. I've never been coached.
21 MR. LEOPOLD: Objection.
22 BY MR. TEIN:
23 Q. Okay. When your counsel that it was there
24 was lack of foundation, you agree with your counsel,
25 right?
115
1 A. I was like saying, Yeah, let's move on,
2 because there was no point to asking that question.
3 Q. Your father threw out of the house
4 because she was lying, correct?
5 MR. LEOPOLD: Objection. Lack of
6 foundation.
7 Hold on, Let me just make the
8 objection.
9 Lack of foundation, predicate, calls for
10 speculation.
11 BY MR. TEIN:
12 Q. Answer.
13 A. I'm not my sister. I don't know.
Page 98
HOUSE OVERSIGHT 012493
-0929104.TXT
14 Q. I want to know what you know only.
15 A. I don't know.
16 Q. You don't know. That's your answer?
17 A. Yes.
18 Q. Now your parents filed the police report
19 regarding Mr. Epstein, right?
20 A. Yes.
21 Q. Now your parents are also lying, aren't
22 they?
23 A. Yes.
24 MR. LEOPOLD: Just so the record is clear,
25 the father -- because the mother was up north.
116
1 MR. TEIN: Don't testify, Counsel.
2 MR. LEOPOLD: So the record is clear, the
3 father -- the mother was --
4 MR. TEIN: Counsel, don't coach and
5 testify, please. That's absolutely improper.
6 MR. LEOPOLD: You just asked the wrong
7 question.
8 MR. TEIN: You can't coach her that way and
9 you well know it.
10 MR. LEOPOLD: For the record, it's the
11 father. He's remarried, I think on his third
12 marriage.
13 MR. TEIN: You cannot -- it's absolutely,
14 totally against the rules and you know it.
15 MR LEOPOLD: The natural mother lives in
16 Georgia.
17 MR TEIN: You need to behave yourself,
Page 99
HOUSE OVERSIGHT 012494
-0929104.TXT
18 lawyer.
19 MR LEOPOLD: The natural mother lives in
20 Georgia. The father is here locally.
21 MR TEIN: Stop coaching. Stop talking.
22 You object. You know the rules. You just
23 lectured me about the rules, Counsel. So why
24 don't you play by the rules. Or only when they
25 fit you? Why don't you grandstand a little more
117
1 now. Give us a five-minute speech, Mr. Leopold.
2 MR. LEOPOLD: Are you finished, for the
3 record.
4 MR. TEIN: I'm not talking to you. Do what
5 you want.
6 MR. LEOPOLD: Don't say anything yet.
7 BY MR. TEIN:
8 Q. your parents --
9 MR. LEOPOLD: Hold it. Don't say anything
10 yet. Let me --
11 BY MR. TEIN:
12 Q. Your parents, who filed the police report
13 are also liars.
14 MR. LEOPOLD: Don't answer the question.
15 We're not going to answer until I make the record.
16 I want to put on the record, now that Counsel
17 appears to be finished with his comments for the
18 record, that the previous question was
19 inappropriate, was intentionally misleading.
20 Now you can ask the question.
21 BY MR. TEIN:
22 Q. Your parents, who filed the police report
Page 100
HOUSE OVERSIGHT 012495
-0929104.TXT
23 in this case, are also proven liars, aren't they?
24 MR. LEOPOLD: Same objection.
25 BY MR. TEIN:
118
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 frae?
17
18
19 •i DS
20
21
22
23
24
25
Q. Aren't your parents liars?
MR. LEOPOLD: Calls for speculation. Lack
of predicate.
MR. TEIN: Stop coaching. You know what
that is, Leopold.
MR. LEOPOLD: Calls for speculation. Lack
of foundation.
THE WITNESS: When you say parents, my mom
is not, but sure, yeah, my dad has been to jail
for lying.
BY MR. TEIN:
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MR. LEOPOLD: You can answer if you know
the answer to it. I have no idea.
Page 101
HOUSE OVERSIGHT 012496
-0929104.TXT
119
1 THE WITNESS: Yeah.
2 BY MR. TEIN:
3 Q. And your father filed a lawsuit, the first
4 lawsuit for fifty million dollars against Mr. Epstein
5 without consulting you, correct?
6 A.OttOtE
7 Q. And your father had a lawyer file the first
8 lawsuit on your behalf for fifty million dollars against
9 Mr. Epstein without your knowledge, correct?
10 A. Correct
11 Q. And you don't trust your father, do you?
12 A. Correct.
13 Q. And you believe he's trying to manipulate
14 you for his own gain, don't you?
15 A. Sort of.
16 Q. Well, you know that your mother filed a
17 statement, an affidavit, saying that you don't trust your
18 father and that you believe he's trying to manipulate you
19 for his own gain; isn't that correct?
20 A. Correct.
21 Q. You agree with that statement, don't you?
22 A. Uh-huh. Yes.
23 Q. Do you trust your stepmother?
24 A. My stepmother, no.
25 Q. You think she's also trying to steal your
120
1 Epstein lawsuit money away from you, don't you?
2 A. I would like to clarify something. You
3 keep saying my Epstein lawsuit money. I don't have any
4 money, and it's just a lawsuit at the moment. So I just
Page 102
HOUSE OVERSIGHT 012497
-0929104.TXT
5 don't trust her.
6 Q. Okay. You think that your stepmother is
7 trying to take advantage of this lawsuit to try to get
8 money from Mr. Epstein that belongs to you, right?
9 A. Yes.
10 Q. Did your stepmother tell you why she was
11 arrested?
12 A. No.
13 Q.
Did your stepmother tell you that she's
14 ever been arrested?
15 A. No.
16 Q. Did she tell you she was arrested for
17 fraud?
18 A. Never.
19 Q. Did she tell you that she was fired from
20
21 A. No.
22 Q. Did she tell you that whe was fired from
23 for stealing?
24 A. No.
25 MR. TEIN: Let's take a break.
1
2 BY MR. TEIN:
3
121
(Thereupon, a recess was taken.)
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Page 103
HOUSE OVERSIGHT 012498
11
12
13
14
15
16
17
18
19
20
-0929104.TXT
9 A. Two.
10 Q. How old were they?
A. Zack being one year older than me,
and then the other person was two years older than me.
Q. What was his name?
A. Ryan
Q. How old were you when you first had sexual
intercourse?
4P 44*
Q. How many -- before you met Epstein, how
many different men had you had any type of sexual
activity with?
21 la AtOtabg$03-0
22 Q. Are you saying you never kissed a man other
23 than those two?
24 MR. LEOPOLD: Objection to the form of the
25 question.
1 THE WITNESS: Yes, I had kissed people
2 before.
3 BY MR. TEIN:
4 Q. Before you met Epstein, had you ever had
5 oral sex?
6 A. No.
7 Q. Ever in your life, have you exchanged sex
8 for something of value?
9 A. No.
10 MR. TEIN: We're done.
11 THE WITNESS: Oh, okay.
12 MR. LEOPOLD: We'll read.
13 MS. BELOHLAVEK: I don't have any
Page 104
122
HOUSE OVERSIGHT 012499
-0929104.TXT
14 questions. Thank you.
15 MR. LEOPOLD: Before we go off the record,
16 it's my understanding -- Mr. Goldberger can
17 correct the record, but we have stipulated that
18 color copies of the documents that were identified
19 for identification certainly will be attached to
20 the deposition and counsel will be taking the
21 photographs across street so that they can be
22 laser color copied so that we have a copy, and I'm
23 assuming he'll get a copy to the court reporter,
24 too, to attach, actually a certified copy to the
25 deposition.
123
1 MR. GOLDBERGER: Done.
2 MR. LEOPOLD: That's if you agree to that.
3 If not, then I want to pull each one out and put
4 exhibit labels on them, which we should do before
5 we leave.
6 MR. GOLDBERGER: We're not going to do
7 either. I'll have copies sent to the court
8 reporter and she can attach them to the
9 deposition.
10 MR. LEOPOLD: So you're not going to agree
11 to what we talked about during the break then.
12 MR. GOLDBERGER: I'm not quite sure what
13 your asking me to do. Let me finish.
14 MR. LEOPOLD: Okay. Sure. That's fine.
15 MR. GOLDBERGER: Okay. If you want me to
16 go over to Ms. Belohlavek's office and make copies
17 and then I'll give those to the court reporter,
Page 105
HOUSE OVERSIGHT 012500
-0929104.TXT
18 fine. All I'm saying is that I would avoid that
19 process. I would send copies to the court
20 reporter. But if it will make you happier
21 MR. LEOPOLD: I'm not?
22 MR. GOLDBERGER: Let me finish.
23 MR. LEOPOLD: I'm not interrupting now.
24 MR. GOLDBERGER: But if it will make you
25 happier if I go over to Ms. Belohlavek's office
124
1 and make a copy of those photos that were part of
2 this deposition and then I'll give them to the
3 court reporter, I'll be happy to do it.
4 MR. LEOPOLD: I trust you implicitly,
5 however you with to do it. However, the
6 documents, before they leave this room, need to
7 have an exhibit sticky on them with the
8 appropriate --
9 MR. GOLDBERGER: Want to go get some? We
10 don't have any.
11 MR. LEOPOLD: I will do that. Excuse me.
12 Let me finish the record, please. You can't do
13 that to the court reporter. She's going to stroke
14 out. You can't do that. You have to let me --
15 MR. TEIN: Finish your sentence, Ted. You
16 are the most long-winded lawyer I've ever seen in
17 my life. Finish your sentence.
18 MR. LEOPOLD: Jack, tell him not to raise
19 his voice, please.
20 MR. TEIN: Finish your sentence. Is there
21 going to be a period at the end of the sentence or
22 is it just going to be comma after comma after
Page 106
HOUSE OVERSIGHT 012501
-0929104.TXT
23 comma?
24 Go ahead, lawyer.
25 MR. LEOPOLD: All right. The exhibits, I
125
1 can't prevent you from taking them, but I will
2 object and I will be bringing it to the court for
3 sanctions. You cannot take the exhibits out of
4 the room without them being marked. I want them
5 marked, because you cannot identify in the record
6 what was used. And with all due respect to
7 Mr. Goldberger, I do not -- the way this
8 deposition is going, I do not want to rely on
9 Counsel from Miami to mark the appropriate
10 exhibits. I will not do that. I cannot prevent
11 you from taking them. But if you do, I will be
12 bringing the matter to the court with appropriate
13 sanctions, because that is improper. That is
14 improper. When you use something in a deposition,
15 they are to be marked. And you have refused to do
16 that throughout for what ever reason.
17 MR TEIN: You're wrong. Finish your
18 sentence because you're talking about something
19 you have no idea.
20 Every single one is marked, Ted. Every
21 single one is already marked. But you want to
22 argue about everything. Ever single one is
23 already marked. Isn't that silly, Ted?
24 MR. GOLDBERGER: Thirty years of doing this
25 and I have never had an argument over this.
Page 107
HOUSE OVERSIGHT 012502
-0929104.TXT
126
1 MR. TEIN: You've made -- Ted, you are
2 obstructionist, you are a liar. You have lied and
3 misrepresented things, for the record. You are
4 grandstanding.
5 MR. LEOPOLD: You need to back up.
6 MR. TEIN: No, no. I'm going to finish.
7 MR. LEOPOLD: You can finish, but don't
8 hover over me.
9 MR. TEIN: No one is hovering over you.
10 Stop trying to make a lying record.
11 Let me say something else.
12 Don't you dare threaten me with sanctions,
13 after you lied in a letter to my co-counsel about
14 the fact -- be quiet. Be quiet and let me finish.
15 You lied in a letter to my co-counsel,
16 Mr. Leopold, in which you said -- it was a
17 complete and utter lie -- that you were
18 unavailable this morning because you had a
19 hearing. That was a lie. I have never seen each
20 lawyer deign to do something like that.
21 So you will get the ex -- be quiet Let me
22 finish. You behave.
23 MR. LEOPOLD: Don't point your finger at
24 me.
25 MR. TEIN: Listen. Be quiet and I won't
127
1 have a need to point it at you.
2 MR. LEOPOLD: Don't point your finger at
3 MR. TEIN: Mr. Leopold --
4 MR. LEOPOLD: Don't point your finger at
Page 108
HOUSE OVERSIGHT 012503
-0929104.TXT
5 me.
6 MR. TEIN: Mr. Leopold, let me finish.
7 MR. LEOPOLD: Don't raise your voice
8 either.
9 MR. TEIN: Mr. Leopold
10 MR. LEOPOLD: Jack, do you want to take
11 care of this?
12 MR. TEIN: Let me finish my sentence. The
13 exhibits are marked. We are walking out of here.
14 You are someone who misrepresents the
15 record. It is absolutely atrocious what you do.
16 That is not how a lawyer should behave. This
17 deposition is over. You will get your exhibits,
18 Mr. Leopold.
19 MR. GOLDBERGER: I understand what you're
20 saying, Michael, and I understand Ted's position.
21 Just so there's -- we're going to have lots
22 offer issues in this case. We're going to have
23 lots of reasons to disagree.
24 I'm going to take it over now and I'm going
25 to make copies and I'm going to give them to
128
1 Ms. Consor. If you want to go find some exhibit
2 labels and put some exhibit labels on it, be my
3 guest. But that's what I'm offering to do.
4 THE WITNESS: Let me say two things,
5 because I am happy to always disagree and with
6 you, I have no problem; we could always do it
7 professionally.
8 I want to say two things so the record is
Page 109
HOUSE OVERSIGHT 012504
-0929104.TXT
9 very clear. Since for whatever reason I have not
10 been able to look at exhibits because they have
11 been refused to have been shown to me --
12 MR. TEIN: That's a lie.
13 MR. LEOPOLD: Jack, if you represent that
14 the documents have the appropriate exhibit numbers
15 or some identifying markings, 25, 30.000, whatever
16 they may be, then you can take them, make copies,
17 send me a copy, make sure the court reporter gets
18 a copy and then send me a bill for my copy, that's
19 fine. I didn't know that they are marked that way
20 because I haven't been able to look at them.
21 MR. GOLDBERGER: They are barcoded and the
22 number that we've made reference to in the
23 deposition coincides with the barcoding.
24 MR. LEOPOLD: That's fine. Eight by eleven
25 color laser copies are fine.
129
1 MS. BELOHLAVEK: The State Attorneys Office
2 is not going to charge anybody for color copies I
3 print out.
4 MR. LEOPOLD: That's fine He's going to
5 take them back to his office .
6 Secondly -- and I will be more than happy
7 to do it, because it sounds like you all know more
8 about it than I, but I'm happy to get affidavits
9 from Mr. Pincus, Judge Stern, everybody else about
10 what happened with this hearing today, because I
11
12
13
know very little about it. But my representations
are what they are.
MR. GOLDBERGER: They stay --
Page 110
HOUSE OVERSIGHT 012505
-0929104.TXT
14 MR. LEOPOLD: Let me just finish for the
15 record.
16 Representations or comments about what
17 happened, representation about this hearing this
18 morning, I know very little about it. I --
19 MR. GOLDBERGER: I'll take your word on
20 that.
21 MR. LEOPOLD: No, no, no. I just put it on
22 the record. I will get an affidavit -- I'm
23 assuming it sounds like you need it -- from Mr.
24 Pincus. I have no clue about what happened and
25 why it was canceled. All I was told when I was
130
1 out of town yesterday was that the hearing this
2 morning was cancelled.
3 MR. GOLDBERGER: I'll take your word for
4 it.
5 MR. LEOPOLD: If you want an affidavit,
6 I'll get it for you.
7 MR. GOLDBERGER: It's a personal issue for
8 me because I had to disrupt a vacation and if it
9 was done just because it wasn't convenient for
10 you, then I'm offended by that. But if you're
11 telling me that it was planned and it didn't
12 happen, I'll take your word for it.
13 MR. LEOPOLD: I am more than happy to get
14 you an affidavit, because I don't know the reason
15 why it was canceled other than the fact that I'm
16 assuming since my deposition was taken for four
17 hours on Monday for preparation for the hearing
Page 111
HOUSE OVERSIGHT 012506
-0929104.TXT
18 today, for whatever reason it was canceled, I am
19 told it is being re-noticed. Why it was canceled
20 I have no idea, but if your co-counsel wishes an
21 affidavit to that effect from Mr. Pincus, I'm more
22 than happy to get it. But I don't know the reason
23 why it was canceled.
24 MR. TEIN: I don't need it. But what I do
25 take issue with is regardless of why it was
131
1 canceled, you owed us the courtesy of saying, you
2 know what? We can start earlier this morning.
3 MR. LEOPOLD: I owe you nothing
4 MR. TEIN: I don't care. Don't interrupt
5 me.
6 Because Jack canceled his vacation plans
7 because of you.
8 MR. GOLDBERGER: That's all right, that's
9 all right.
10 MR. TEIN: And you're selfish. And this
11 deposition is over. Good-by Mr. Leopold.
12 MR. GOLDBERGER: You can go off the record.
13 - - -
14
15
16
17
18
19
20
21
22
Page 112
HOUSE OVERSIGHT 012507
-0929104.TXT
23
24
25
132
1 CERTIFICATE
2 - - -
3
4 The State of Florida,
5 County of Palm Beach.
6
7 I hereby certify that I have read the
8 foregoing deposition by me given, and that the statements
9 contained herein are true and correct to the best of my
10 knowledge and belief, with the exception of any
11 corrections or notations made on the errata sheet, if one
12 was executed.
13
14
15 Dated this _______day of___________________, 2008.
16
17
18
19
20
21
22
23
24
25
Page 113
HOUSE OVERSIGHT 012508
-0929104.TXT
133
1 DATE: [!MONTH2] DATE2, 2008
2 TO:
X
3 X
X, Florida X
4
IN RE: CASENAME
5 CASE NO.: 2006 CF09454AXX
6 Please take notice that on Wednesday, the
DATE1 of [!MONTH1], 2008, you gave your deposition in the
7 above-referred matter. At that time, you did not waive
signature. It is now necessary that you sign your
8 deposition.
A Please call our office at the below-listed
9 number to schedule an appointment between the hours of
9:00 a.m. and 4:30 p.m., Monday through Friday.
10 AAs a professional courtesy, I am enclosing
a condensed copy of your deposition transcript.
11 A As previously agreed to, the transcript
will be furnished to you through your counsel. Please
12 read the following instructions:
At Page A of the transcript, you will find
13 an errata sheet. As you read your deposition, any
changes or corrections that you wish to make should be
14 noted on the errata sheet, citing page and line number of
said change. DO NOT write on the transcript itself.
15 Once you have read the transcript and noted any changes,
be sure to sign and date the errata sheet and return
16 these pages. You need not return the entire transcript.
If you do not read and sign the deposition
17 within a reasonable time, the original, which has already
been forwarded to the ordering attorney, may be filed
18 with the Clerk of the Court. If you wish to waive your
signature, sign your name in the blank at the bottom of
19 this letter and return it to us.
Very truly yours,
20
21 Judith F. Consor, FPR
Consor & Associates Reporting and Transcription
22 1655 Palm Beach Lakes Boulevard, Suite 500
West Palm Beach, Florida 33401
23
I do hereby waive my signature:
24
25 SAIGE GONZALEZ
134
1 cc via transcript: JACK A. GOLDBERGER, Esquire
LANNA BELOHLAVEK, Esquire
2 MICHAEL R. TEIN, Esquire
file copy
3
4
Page 114
HOUSE OVERSIGHT 012509
-0929104.TXT
5
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9
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135
1   ERRATA   SHEET
2   IN RE: CASENAME
DEPOSITION OF:   TAKEN: [IMONTH1]
3   DATE1, 2008
DO NOT WRITE ON TRANSCRIPT   - ENTER CHANGES HERE
4   PAGE # LINE # CHANGE   REASON
5
6
7
8
Page 115
HOUSE OVERSIGHT 012510
-0929104.TXT
9
10
11
12
13
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15
16
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20
21 Please forward the original signed errata sheet to this
office so that copies may be distributed to all parties.
22
Under penalty of perjury, I declare that I have read my
23 [!TYPE] and that it is true and correct subject to any
changes in form or substance entered here.
24
DATE:___________ SIGNATURE OF DEPONENT:_______________________________
25
136
1 THE STATE OF FLORIDA,
2 COUNTY OF PALM BEACH.
3
4
5 I, the undersigned authority, certify that
6 personally appeared before me on the DATE1
7 of [IMONTH1], 2008 and was duly sworn.
8
9 WITNESS my hand and official seal this DATE2
10 day of [IMONTH2], 2008.
11
12
13
Page 116
HOUSE OVERSIGHT 012511
-0929104.TXT
14
15
16
17
18
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22
23
24
25
Judith F. Consor, FPR
Notary Public - State of Florida
137
1 CERTIFICATE
2
The State Of Florida,
3 County Of Palm Beach.
4
5 I, Judith F. Consor, Court Reporter and Notary
Public in and for the State of Florida at large, do
6 hereby certify that I was authorized to and
stenographically report the [!TYPE] of
7 that a review of the transcript was not requested; and
that the foregoing pages, numbered from 1 to A,
8 inclusive, are a true and correct transcription of my
stenographic notes of said [!TYPE].
9
1 further certify that said [JTYPE] was
10 taken at the time and place hereinabove set forth and
that the taking of said [ITYPE] was commenced and
11 completed as hereinabove set out.
12 I further certify that I am not an attorney or
counsel of any of the parties, nor am I a relative or
13 employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
14 action.
15 The foregoing certification of this transcript
does not apply to any reproduction of the same by any
16 means unless under the direct control and/or direction of
the certifying reporter.
17
DATED this DATE2 day of [!MONTH2], 2008.
Page 117
HOUSE OVERSIGHT 012512
-0929104.TXT
18
19
20
21
22
23
24
25
Judith F. Consor, Court Reporter
Florida Professional Reporter
Page 118
HOUSE OVERSIGHT 012513
TAB 14
HOUSE OVERSIGHT 012514
sor &Associates
Favor** gnfl Triamaipeoa,
Page 1
THE STATE OF FLORIDA,
COUNTY OF PALM BEACH.
IN RE:
JEFFREY EPSTEIN.
SWORN STATEMENT OF
Friday, March 21, 2008
4:00 p.m. - 4:20 p.m.
250 Australian Avenue South
Suite 1400
West Palm Beach, Florida 33401
Reported By:
Judith F. Consor, FPR
Notary Public, State of Florida
Consor & Associates Reporting and Transcription
West Palm Beach Office
Phone - 561.682.0905
HOUSE OVERSIGHT 012515
sor & Associates
Page 2
1 APPEARANCES:
2
On behalf of the Defendant:
3 JACK A. GOLDBERGER, ESQ.
ATTERBURY, GOLDBERGER & WEISS
4 250 AUSTRALIAN AVENUE SOUTH
SUITE 1400
5 WEST PALM BEACH, FLORIDA 33401
561.659.8300
6
ALSO PRESENT
7 LILLY ANN SANCHEZ, ESQ.
FOWLER WHITE, ATTORNEYS AT LAW
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
^
HOUSE OVERSIGHT 012516
Statement taken before Judith F. Consor,
Court Reporter and Notary Public in and for the State of
Florida at Large, in the above cause.
5 Thereupon,
having been first duly sworn or affirmed, was examined
and stated as follows:
THE WITNESS: I do.
10 BY MR. GOLDBERGER:
11 Q. Would you state your name for the record,
12 please.
13 A.
14 Q. Okay. 111111111 where do you live now?
15 A. Address?
16 Q. Sure.
17 A.
18
19 Q. Do you live there alone or do you live with
20 somebody there?
21 A. My father.
22 Q. Very good. And are you working now or not
23 working? Sometimes you work and sometimes you don't?
24 A. When I want to.
25 Q. Okay. And how old are you today?
HOUSE OVERSIGHT 012517
sor 87, Associates
RoporringandTrawipifico,
Page
1
2
3
4
5
6
A. Twenty-one.
Q. Very good.
What we're going to do today is we're going
to take what's know as a sworn statement from you. And
my court reporter just put you under oath. So all I want
you to do is tell the absolute truth today.
7 A. Right.
8 Q. I don't want you to color what you're
9 saying in any way. Really, the only thing that will be
10 of any use to anyone is if you just tell the absolute
11 truth.
12 A. Right.
13 Q. So those are the instructions, okay?
14 A. Okay.
15 Q. All right. And sometimes -- I've been
16 doing this for a lot of years and sometimes I talk like a
17 lawyer too much, and if you don't understand what I'm --
18 A. That's your job.
19 Q. I guess. But if you don't understand what
20 I'm saying at some point, just say, "Jack, say it in
21 English," and I'll make it better for you. Okay?
22 A. Okay.
23 Q. So tell me how you first met Jeffrey
24 Epstein.
25 A. introduced me to him.
M,itIAL41A.V&Gt....*teut6t lt8.EAL,6514.
HOUSE OVERSIGHT 012518
5or & A55ociates
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HOUSE OVERSIGHT 012519
sor ez. Associates
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Page 6
1 Q. Okay. So as far as you understood it and
2 as far as what told you, you would be going over to
3 Mr. Epstein's house and just giving him a normal
4 therapeutic massage?
5 A. Right.
6 Q Okay. And I assume told you you would
7 be paid for it?
8 A. Yes.
9 Q Did she tell you how much you would be
10 paid?
11 A. Yes. Two hundred.
12 Q Okay. When was the first time that you
13 went to Jeffrey Epstein's house? Was it after you spoke
14 to Alex?
15
16
17 Mr. Epstein's house, that was in response to
18 talking to you in person. In other words, she said --
19 you saw her somewhere, be it at the store that you worked
20 at or around the neighborhood, she said to you in person,
21 "Do you want to go over to Jeffrey Epstein's house?"
22 Right?
23
24 4 110n6000
A.
Q.
A.
Yes.
Okay. And the first time that you went to
Oh-huh.
HOUSE OVERSIGHT 012520
sor & Associates
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3
5
6
7
a
9
10
11
12
13
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A. Yes.
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And I take it you said okay and you went
Q. All right. Now at the time that you went
over there, you were not yet 18, but you were almost 18?
A. Yes.
Q. You were within a couple of months of being
18 years old?
A. Yes, I do believe so.
Q. Okay. And what did tell you about if
asked, how old you should tell anyone you were when you
went over to his house?
Was that a bad question?
A. Repeat that.
Q. Sure. Okay.
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HOUSE OVERSIGHT 012521
sor & Associates
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HOUSE OVERSIGHT 012522
Page
A. It was probably Jeffrey. I don't remember
very clearly.
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6 ,./.WAOWOOM#01Y0040401C
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A. Yes.
Q. Okay. Now the first time that you went to
10 Jeffrey's house did you give him a massage that day?
11 A. Oh-huh.
12 MS. SANCHEZ: Answer yes or no so the
13 record is clear.
14 THE WITNESS: Yes. Okay.
15 (Discussion held off the record.)
16 BY MR. GOLDBERGER:
17 Q. Okay. So you go to Jeffrey's house and you
18 meet him and you're going to do a massage that day,
19 right?
20 A. Yes.
21 Q ow were°16d ..... you were
22 _,.A04#4#k*$0.#00X
23
24 Q Yu OVO: tv-ored to do anything that you.
25
HOUSE OVERSIGHT 012523
6 massage?
Q. No one offered you any drugs to do a
Q. No one offered you any alcohol to do a
extg- 'Inmeo.sagetromn11
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HOUSE OVERSIGHT 012524
3
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8
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9 when you went there, as far as keeping your clothes on or
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11
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17 Q. All right. So told you there would be
18 no pressure on you whatsoever?
19 A. Right.
20
21
'PDX
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22 Q •
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24
25
Q •
And if you didn't want to do something, you
All right. And in your experiences with
HOUSE OVERSIGHT 012525
&Dr &A5sociate5
.F.gpcstilog mai Trawiipdpao
1
2
3
4
5
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7
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9
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15
16
17
16
19
20
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22
23
24
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Page 12
Mr. Epstein, by the way, was there ever a time when that
didn't play out, when he tried to force you to do
something that you didn't want to do?
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Q. All right.
Now the first time that you wont there do
you remember whether you gave Jeffrey a massage with your
clothes on or your clothes off?
A. At the beginning, it was with all my
clothes on.
Q. Uh-huh.
A. But the most that -- I mean I was still in
my bra and panties.
Q. Okay. The whole time?
A. Yes.
Q. Right.
A. I'm pretty sure, yes.
Q. Did you see during that massage -- did he
try and touch you in any way during that massage?
A. No.
Q.
Did he use any kind of device on you in any
way during that massage?
HOUSE OVERSIGHT 012526
sor & Associates
Tmaxoripfito,
Page 13
1 A. No.
2 Q. Do you know he was wearing a rowel
3 through that massage?
4 A. Yes.
5 Q. Do you know whether he touched himself in
6 any way, his penis or anything like that, during the
7 massage?
8 A. Yeah, like towards the end.
9 Q. Okay. Do you know whether he masturbated?
10 A. Oh, my gosh.
11 Q. If you don't know, you don't know.
12 A. I mean probably, but I don't know. I can't
13 remember exactly. It was so long ago.
19 Q. Okay. There was nothing that you were
15 uncomfortable with in this massage?
16 A. No. Yeah. And like I said, he also, you
17 know, reassured if I wasn't comfortable with anything,
18 then just tell him and --
19 Q. He would stop?
20 A. -- that would be the end of it.
21 Q. Okay. Now after that first time you met at
22 Jeffrey's house, you left. And did there come other
23 times that you went to Jeffrey's house?
24 A. Yes.
25 Q. And how would that occur? How would that
HOUSE OVERSIGHT 012527
1 happen?
2
3
4
5
6
7
8
9
10 dO opp,
11
12
13
14
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16
17
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A. Most of the time.
24
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HOUSE OVERSIGHT 012528
sor & Associates
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2
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10
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Never, ever suggested, right?
A. No.
Q. Okay. The only thing that ever occurred on
any of these phone calls was, "Are you willing to come
over," or, "Would you like to come over and give a
massage?"
A.
Q.
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Q. Okay. The phone call from or any
other assistant would always -- it would be sporadic,
right? They always said, "Jeffrey's going to be in town.
Do you want to come over this afternoon at four o'clock?"
A. Yeah, yeah. It wasn't --
Q. There was nothing regular about it?
A. No.
Q. Okay. Other than who else would have
called you to ask whether you wanted to come over and
HOUSE OVERSIGHT 012529
cr & Amoriates
Ropartin mxt Trmu
give a massage?
2
Page 16
A. If it wasn't then I believe 11111111
3 maybe one other person I don't know the name of. Just --
4 I mean it was mostly And I spoke to a time
5 or two.
6 Q.
7 Jeffrey's house after getting a phone call, you would go
8 and you'd go to give him a massage, right?
9 A. Yes.
10 Q.
11 massage that occurred?
12 A. It happened a few times.
13 Q. Okay. And the few times that it happened,
14 though, it was very sporadic and it was nothing that was
15 planned?
16 A. No way.
17 Q. It just occurred?
18 A. Right.
19 Q. So it wasn't like there was a phone call,
20 you know, "Today we want you to come over and do more
2/ than just a massage with Jeffrey"?
22 A. Right.
23 Q. When anything more occurred you'd be over
24 there and it would be totally voluntary on your part?
25 A. Yes; definitely consensual.
XaSIOSING.....4.41,40214.0.1,....aixuar,a1444
Okay. Now when you would go over to
And occasionally would there be more than a
HOUSE OVERSIGHT 012530
Yes.
A.
It was probably mostly -- maybe not, not
particularly oral, but,
ViiibbOth4OMAUMPtatiObit
Q. Okay. So let's put it into perspective.
You certainly never had intercourse with him, right?
A. No.
Q. And did you actually ever really have oral
sex with him?
A. Maybe once or twice. I barely even
remember that.
1 Q.
2 than just
sor & Associates
Rwitveto* Trammip.ft, E.
Page 17 1
Okay. Now when we're talking about more
a massage, what sort of conduct are we talking
3 about that might have occurred?
4
5
6
7
a
9
10
11
12
13
14 Q. Okay.
15 A. I mean it was all just mostly --
16 Q. I'm sorry. Mostly what?
17 A. Mostly like hand oriented.
18 Q. Okay. So on occasion you would touch his
19 penis with your hand?
20 A. It's happened a few times.
21 Q. Okay. And anytime that occurred it would
22 be totally voluntary on your part?
23 A.
24 Q
25 A.He wQuld nvr make me co anythi
' . .
HOUSE OVERSIGHT 012531
sor 8,t Associates
'Wolin =4 TrimoTiptiori, hi.
Page 18
1 Q. And it would just be totally random and it
2 would occur during the moment?
3 A. Uh-huh.
4 Q. Okay. There was nothing that was planned
5 in advance concerning that?
6 A. No.
7 Q. And it didn't become every time you went
8 over there that would happen, right?
9 A. Yeah. No.
10 Q. No, no. I mean just you would go over and
11 give a massage one day and the phone call would be the
12 same, "Do you want to come over and give a massage," and
13 maybe --
14 A. Yes.
15 Q. -- maybe another time you would get a phone
16 call, "Do you want to come over and give a massage," and
17 just because of the day it was or whatever was going on,
18 it may have gone a little further where they may have
19 been some touching, correct?
20 A. Right.
21 Q. And then the next time you could go over
22 there and it could have been a regular massage again,
23 right?
24 A. Uh-huh.
25 Q. Okay. So the point that I guess I'm trying
-uw—ataratsontesagi cwa.alsaftate
1
HOUSE OVERSIGHT 012532
sot- St Associates
orgirat T1$4, tem
1
2
3 and give a massage," and you just assumed it would be to
4 go have sex? That was not the case?
5 A. No.
6 Q. Never, never, never, right?
7 A. Yes.
8 Q. All right. There were times when you would
9 be away and not be in Palm Beach and -- I mean you very
10 much thought that Jeffrey was your friend? You treated
11 him as a friend?
12 A. Yes, definitely. I felt that he was my
13 friend.
14 Q. And there were times when maybe you were
15 out of town and for whatever reason, you found yourself
16 in a situation where you needed some money, correct?
17 A. Yes.
18 Q. Okay. And you felt that the relationship
19 was such that you could call Jeffrey and it never had
20 anything to do with a massage or anything. You would
21 say, "Listen, I could use a couple of dollars. I have a
22 problem."
23 A. Yes.
24 Q. And would he ever hesitate to help you out?
Page 19
to make was that there were never phone calls that would
come to you and they would say, "Do you want to come over
25 A. No.
HOUSE OVERSIGHT 012533
sor & Associates
R*peraganitTrotwriptitv,Inp.
Page 20
1
2 listen -- he would talk to you about life and about --
3 A. Yes.
4 Q. -- about what you wanted to do with your
5 life?
6 A. Yes.
7 Q. And he said, "If you ever find yourself in
8 trouble, you have a friend in me and you can give me a
9 call"?
10 A. Yes.
11 Q. Okay. If you had to guess -- and
12 recognizing that there can be no accuracy here -- if you
13 had to guess, how many times do you think you went over
14 to Jeffrey's house?
15 A. I would say at least five, less than ten.
16 Q. Okay. I think that's kind of a fair range.
17 And during those five to ten times that you
18 went there, was there ever anything uncomfortable, in
19 your mind, that occurred over at Jeffrey's house?
20 A. No.
21 Q. Okay. I know we've touched on this, but
22 just Lilly, the detail person, makes sure that we get
23 everything. After you met Jeffrey the first time did you
24 ever talk to him on the telephone about arranging a
25 massage or anything like that?
Q.
And in fact, did he not tell you that,
HOUSE OVERSIGHT 012534
sor & Associates
TriLcd$,
Page 21
1 A. No.
2 Q. Okay. And you never e-mailed him or
3 anything like that?
4 A. No, no.
5 Q. Never text-messaged him?
6 A. No.
7 Q. Okay. Now at times when you would go over
8 zo give a massage, Jeffrey, while he was getting the
9 massage, would be preoccupied doing a lot of things,
10 right?
11 A. Yes, very often.
12 Q. He was a busy guy?
13 A. Yes.
14 Q. He would be on the telephone talking Lo
15 folks while you were giving a massage?
16 A. Yes. Sometimes it would be just a massage
17 and he'd be pretty much doing business the whole time.
18 Q. Right. Certainly it wasn't sex or anything
19 like that?
20 A. No.
21 Q. He would be doing business and you'd be
22 massaging him?
23 A. Yes.
24 Q. Okay. Give me one second.
25 (Discussion held off the record.)
A
1
HOUSE OVERSIGHT 012535
sor &Associates
pu.tfial5 gad Tomeliptiq'xi,
1 BY MR. GOLDBERGER:
2 Q.
Page 22 3
Every time you went back to Jeffrey's house
3 you went back there because you wanted to, right?
4
5
A. Uh-huh, yes.
Q. No one -- certainly Mr. Epstein never tried
6 to persuade you or induce you or entice you or coerce you
7 to engage in any kind of sex?
8
9
A. No.
Q. And no one representing Jeffrey Epstein
10 ever tried to persuade or induce you to engage in sex?
11
12
A. No.
AU right
'floAVVI
AOgg4444CYOR.
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18 Q. Okay.
19
20 that.
21
'-otYgg0114APIC -
aMAIA
A. Like there was no ifs, ands or buts about
Q. There was a time when there was a concert
22 or a show down in Fort Lauderdale and Jeffrey got you
23 tickets to go to that show because it was your birthday,
24 right?
25 A. Correct.
HOUSE OVERSIGHT 012536
sor & Associates
Rffipsirlin ATP4 TIVitiM46-9A, 11114.
HOUSE OVERSIGHT 012537
sor As5ociate5
Rcipartiag sad nansuripdom, Tn.
1
2 Q.
3 questions, have you?
4 A. Yes.
A. Yes.
Okay. And you've understood all my
Page 24
5 MR. GOLDBERGER: Okay. I thank you very
6 much for coming in today and it really made it
7 much easier for us to do it this way. So thanks a
8 lot.
9
10 concluded at 4:20 p.m.)
11
12
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(Thereupon, the sworn statement was
HOUSE OVERSIGHT 012538
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-sor & Associates
oportima 4114 Trasuiptivq,
Page 25
THE STATE OF FLORIDA, )
COUNTY OF PALM BEACH. )
I, the undersigned authority, certify that
personally appeared before me on the 21 of
March, 2008 and was duly sworn.
WITNESS my hand and official seal this 22nd day
of March, 2008.
Zia'AP4re 41
Judith F. Consor, FPR
Notary Public - State of Florida
4
1
HOUSE OVERSIGHT 012539
sot- & Associates
RcrmingaTWMwmuiptiolOm
1
2
CERTIFICATE
Page 26
The State Of Florida, )
3 County Of Palm Beach. )
4
5 I, Judith F. Consor, Court Reporter and Notary
Public in and for the State of Florida at large, do
6 hereby certify that I was authorized to and did
stenographically report the sworn statement of
V that a review of the transcript was requested; and
that the foregoing pages, numbered from 1 to 24,
8 inclusive, are a true and correct transcription of my
stenographic notes of said sworn statement.
9
I further certify that said sworn statement
10 was taken at the time and place hereinabove set forth and
that the taking of said sworn statement was commenced and
11 completed as hereinabove set out.
12 I further certify that I am not an attorney or
counsel of any of the parties, nor am I a relative or
13 employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
14 action.
15 The foregoing certification of this transcript
does not apply to any reproduction of the same by any
16 means unless under the direct control and/or direction of
the certifying reporter.
17
18
19
20
21
22
23
24
25
DATED this 22nd day of March, 2007.
Judith F. Consor, Court Reporte
Florida Professional Reporter
gaftviiiirobrvidirtaturiaslalbluadiper.61
HOUSE OVERSIGHT 012540
or & Associates
Vollin age4 Tmagaiptilim, I.
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite SOO - West Palm Beach, FL 33401.
Paup 27
HOUSE OVERSIGHT 012541
or & Associates
it*NrCing 4414 ihmip(Tgn, Imo.
Page 28
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
HOUSE OVERSIGHT 012542
nsor .Associates
Thainziptima,
Page 2
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
HOUSE OVERSIGHT 012543
sor & Associates
wail Tramsliption,
411.1....107.11____________________________________
Page 30
uIIIIIIII.II.uI-j
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
HOUSE OVERSIGHT 012544
TAB 15
HOUSE OVERSIGHT 012545
nsor A5sociate5
parlirps... and. Immeripti:ca,laa:
THE STATE OF FLORIDA.
COUNTY OF PALM BEACH.
IN RE:
JEFFREY EPSTEIN,
Page 1
CONTINUED SWORN STATEMENT OF
March 26, 2008
6:05 p.m. to 6:22 p.m.
South 86th Terrace
West Palm Beach, Florida
Reported By:
Maria C. Powers,
Notary Public State of Florida
J. Consor & Associates
West Palm Beach Office
Phone 561.682.0905
Reporting & Transcription
ORIGINAL
Ph. 561.682.0905 - Fax. 561.682.1771
• " —1655"PaIM Beach Lakes Blvd.;-Silite 500 - West Palm Beath, FL 33401 '
HOUSE OVERSIGHT 012546
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nsor & Associate5
17-1,..tporgirnS n d TrIviscrirziva„
1 APPEARANCES :
2
3
4 On Behalf of the Defendant:
JACK A. GOLDBERGER, ESQ.
5 ATTERBURY, GOLDBERGER & WEISS
6 250 South Australian Avenue
Suite 1400
West Palm Beach, Florida 33401
Page 2
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes BlVd., Suite 500 West-Palm Beath, FL 33401
HOUSE OVERSIGHT 012547
nsor Atisociate5
g *port iTis :pn•ki TF,Inscrip inn .
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Pahl Beach Lakes Blvd., Suite 500 - West Palm Beach,-FL-33401' •
HOUSE OVERSIGHT 012548
nor A55ociate5
Tptrix4-1T.tigq,
1
2
3
4
5
6
7
8
9 BY MR. GOLDBERGER:
10
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12
13
14
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16
17
18 A Yes.
19
20
21
22
23
24
25
Page 4
Sworn Statement taken before Maria Powers,
Court Reporter and Notary Public in and for the State
of Florida at Large, in the above cause.
Thereupon,
having been first duly sworn, was examined and
testified as follows:
DIRECT EXAMINATION
as you remember, my name is Jack
Goldberger. I think we met last Friday, actually.
You voluntarily came in and gave a sworn
statement to me concerning your knowledge and your
friendship with Jeffrey Epstein.
I would like to very, very, briefly continue
that statement today, and just focus on one area that
we forgot to question you about last Friday.
All I want you to tell me is the absolute
truth here this evening. There's no right answer,
other than the truth, okay?
A Right.
I haven't promised you or asked you to do
anything, one way or the other, have I?
A No.
Ph. 561.682.0905 - Fax. 561.682.1771
— 1655 Pah Be'ath-Lakes BlVd.-;-Suite 500 - West Palm Beach, FL-33401 " •
HOUSE OVERSIGHT 012549
nsor Assocate5
. , ge'.11Prtirls -.9nd rm:ri,_10c. • - - • • •
Page 5
1 Q So, we covered a lot of ground last time.
2 One area that I didn't ask you about is
3 contact that you've had with either the FBI or the U.S.
4 Attorney's Office, within the last two or three years.
5 Can you guess or estimate how many times
6 someone from the FBI or the U.S. Attorney's Office or
7 some other law enforcement agency, has attempted to
8 contact you in the last couple of years?
9 A I'd have to say -- well, maybe five or six
10 meetings with, and more than that with phone contact.
11
Let's try to break it down by meetings and
12 phone contacts. I think that would be the best way to
13 do it.
14 Of the actual meetings that you've had with
15 someone from law enforcement or from the U.S.
16 Attorney's Office, who do you remember being present at
17 those meetings?
18 A Nesbith was at all of them.
19 Q When we're talking about "Nesbith" we're
20 talking about an FBI agent by the name of "Nesbith
21 Kurkendall"?
22 A Yes.
23 Q And Nesbith was present at all those
24 meetings?
25 A Yes.
Ph. 561.682.0905 - Fax. 561.682.1771
-1655. Pah Beath. Lakes'Blvd.;Suite- 500' •- West Pah-Reach-, FL 33401 '
HOUSE OVERSIGHT 012550
-nsor & Associates
•.., ,.. •
Page 6
1
2 A The first one was a guy, I'm not sure of his
3 name. And then there's another one that had -- another
4 lady with the victim's rights.
5 Q She was victim's right representative?
6 A Yes.
7 Q We talked about a lawyer by the name "Marie
8 Villafona;" do you know whether she was present during
9 any of those meetings?
10 A I'm not sure of the name.
11 Q The first time that you met with Nesbith,
12 where did that take place?
13 A Here, in my backyard.
14 0 In your backyard, at your home in Western
15 Palm Beach County, right?
16 A Yes.
17 Q Did she announce to you that she was coming,
18 or did she just show up?
19 A She showed up.
20 Q Unannounced?
21 A Yes.
22 Q During that time, I assume that you told her
23 about your relationship with Jeffrey Epstein and any
24 contact you've had with him, correct?
Q Okay, go ahead.
25 A Correct.
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palen Beath-Lakes.B1\id., Suite 500 =West Palrn' Begth;R:33401 ' • -•
HOUSE OVERSIGHT 012551
nsor & A550cates
- • gclprtimr... *!11•Tr;g3gripti;;
Page 7
1 Q Did she tell you anything about whether you
2 were a victim in this case, or anything like that, at
3 that meeting?
4 A Yes, she said I was a victim/witness in this,
5 and that there's victim rights that I'm entitled to,
6 which include counseling and whatnot.
7 Q Did you tell her, at that time, that you
8 didn't feel that you were a victim at all, and that
9 anything that you've done with Jeffrey Epstein was
10 totally voluntary?
11 A Yeah, I did tell her that everything was, you
12 know, consensual with everything, and I don't agree
13 with anything that's going on.
14 Q Did she try and pressure you into being a
15 victim in this thing, when you were not a victim?
16 A I wouldn't say that she pressured me, but she
17 tried to be as convincing as possible.
18 Q Maybe the use of the word "pressure" is too
19 strong. But she was trying to change your opinion of
20 what the relationship was with Jeffrey?
21 A Yes, she was trying to make me feel bad about
22 it, in a way, about what was going on.
23 Q And you didn't feel bad about it, you felt
24 everything was okay, but she was trying to make you
25 feel bad, like something wrong had occurred?
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm- Beath Lakes BlVd.','Suite 500 - West Palm Beath', FL 33401" "
HOUSE OVERSIGHT 012552
nsor Associates
• Ita.pon:1112 iapd TF4-05criT•girpr.) 5716, • •
Page 8
1 A Yeah.
2 Q How long did that meeting go on for?
3 A Probably about -- at least an hour.
4 Q When was the next time that you had contact
5 with Nesbith or someone else from law enforcement?
6 A I'm not sure, probably a month or later. I
7 mean, she probably called me and let me know that she
8 was going to -- you know, she wanted to meet sometime
9 soon, to deliver the victim's rights papers to me.
10 Q So there was a time, after you first met,
11 where, despite the fact that you said, I don't consider
12 myself a victim in this, she called you and said, I
13 want to bring you some paperwork that talks about your
14 victim's rights?
15 A Yes.
16 Q What was your response to her when she told
17 you that?
18 A I told her I would meet with her, 'cause she
19 wanted me to meet with the other woman involved. And
20 they gave them to me.
21 I took them, but I never really told them I
22 needed counseling or anything like that.
23 Q Where did that meeting take place?
24 A I believe it was Panera Bread in
25 Wellington.
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm'Beach.Lakes Blvd., Suite 500 West"Palm Beach, FL 33401 "
HOUSE OVERSIGHT 012553
rt
nsor & Assoaate5
RepprOng
Page 9
1
She actually came and sought you out at a
2 restaurant?
3 A Well, I told her to meet me there.
4 Q Were you working there or were you just --
5 A No, I was just there.
6 Q So she called you and said, I really, really
7 want to see you. And you said, if you want to see me,
8 meet me at Panera Bread?
9 A Yes.
10 Q Did you feel if you didn't meet her, she
11 wasn't going to go away, that you had to deal with
12 her?
13 A Well, I mean, it wasn't particularly that. I
14 knew that she was going to contact me because of this
15 case. Because, whether I want to be involved or not, I
16 have to be.
17 Q Okay. That's two meetings that I know of. I
18 think you indicated that, if you had to guess, there
19 were maybe a total of five meetings.
20 Are there other meetings that we haven't
21 talked about that occurred?
22 A Yeah, but they were very vague They weren't
23 anything of importance. And, I mean, it was just
24 her -- or of importance to me, anyway.
25 Q Would she call you and say, listen, I really,
Ph. 561.682.0905 - Fax. 561.682.1771
' .1655 Palm Beach Lakes-Blvd., Suite 500 - West"Pairn Beath; FL 33401
HOUSE OVERSIGHT 012554
nsor & As5ociate5
Repo.rti-ps .4nAl Tmo.3,;:rivrAp,. rhrfc,,;
Page 10
1 really, want to talk to you about being a victim or --
2
A It wasn't always directly about being a
3 victim. And, every-time we talked, she would always
4 touch upon the fact that if I need any help or
5 so-on-and-so-forth, because I am a victim in this
6 case.
7 Q I assume, based on what you're telling me,
8 you continued to tell her, I'm not a victim?
9 A I just let her say what she said. I never
10 got counseling. But she knows from the beginning, and,
11 I continued to reassure her, that I don't feel that
12 way.
13 Q So, the first time you met with her, when you
14 spent about an hour with her and you went through all
15 your contact with Jeffrey, that's what occurred at that
16 meeting, and she talked to you about being a victim at
17 that meeting?
18 A Yes.
19 Q And then there was this second meeting, where
20 she brought a victim's rights person with her, and that
21 took place at Panera Bread, right?
22
A Yes.
23 Q And you had the same response, listen, you
24 think I'm a victim. You could give me the information,
25 but I don't need that information, right?
Ph. 561.682.0905 - Fax. 561.682.1771
' 1655 Pah Beach Lakes BlVd., Suite`500 -Vest Palm Beath, FL 33401—
HOUSE OVERSIGHT 012555
nsor & Associates
Reef or0:1:1... 44p11.1.1,-Fin5sqiir4im, • .
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A Right, pretty much.
And then there were some other contacts.
Would she call you and want to talk to you
4 about the specific facts about the case? I mean, why
5 would she contact --
6 A Yeah, I mean, just to re-question me about
7 certain things, because she wasn't sure that the
8 answers were --
9
Were those in-person meetings?
10 A I mean, a lot of them were on the phone. I
11 mean, it wasn't very often that we would meet.
12 Q Was there any other time that you did meet?
13 We talked about two times that you actually
14 did meet, once here at your home and once at Panera
15 Bread.
16 Were there any other actual meetings, or did
17 the others occur on the phone?
18 A There were other meetings, but they were,
19 like I said, not really important.
20 Q Do you remember where they were that they
21 took place?
22 A They came to my job, I think, two times.
23 Q When you say "they" --
24 A Well, it Nesbith the first time, and, the
25 second time, it was the David Copperfield investigators
Ph. 561.682.0905 - Fax. 561.682.1771
••••• • '1655•Pali-n--Bekh• Lakes BlVd.";Suite'500 -"West*Palm-Beach:FL3340•1"--'----
HOUSE OVERSIGHT 012556
nsor & As5ociate5
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Page 12
1 with Nesbith.
2 Q Right.
3 So, the third time that you met with Nesbith,
4 she came to your job, and she wanted to talk to you
5 about more facts of the case?
6 A Ah-huh.
7 Q And, during that meeting, she also talked to
8 you about your rights as a victim again?
9 A Yeah, she always reassured me of my rights as
10 a victim.
11 Q Then there would have been a fourth time
12 we're talking about now, where there were investigators
13 from Washington coming down, concerning David
14 Copperfield, and Nesbith introduced them to you,
15 correct?
16 A Right.
17 Q I take it what you're telling me is that
18 Nesbith seized the opportunity to talk to you again
19 about being a victim, right?
20 A She always kind of comes out as asking if I'm
21 okay, and if everything okay. And if I ever need any
22 kind of help or anything, with -- you know, I could
23 always have help.
24 Q Did you continue to say, listen, I'm fine,
25 there's no issues here?
3
Ph. 561.682.0905 - Fax. 561.682.1771
Palhi.Bektitake't•BIVtl":,'SOite-500",, We8t-Palhi Beath, FL '33401 "
HOUSE OVERSIGHT 012557
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A I just -- I mean, I was never pushy on it. I
2 just, like I said, she always knows.
3 I may not tell her every time, but she always
4 knows how I feel about this case.
5 Q Meaning?
6 A I don't need any-thing.
7 Q Meaning that you made it really clear to her
8 that you didn't need any help?
9 A Yeah, from the beginning, I was very, very
10 reassuring about how I felt about it. And I wasn't
11 very happy.
12 Q All right. I understand.
13 Now, we're about four contacts with
14 Nesbith your house, Panera Bread, work, the David
15 Copperfield investigators.
16 A Yes.
17 Q Were there any other meetings that we have
18 not spoken about?
19 A There may have been like one or two. But
20 they're -- I don't even remember. I mean, those are
21 the ones, like, that remember the most.
22 Q That you really remember, okay.
23 Now, were there other telephone calls that
24 occurred, where, kind of the same kind of conversation
25 would occur? You know, there's help for you and you'd
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach•LakOs Blvd:, Suita"500 West Palm'Reath, FL3340r'
HOUSE OVERSIGHT 012558
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Page 14
1 say, I'm really not a victim here?
2 A Like I said, I was, like, okay. You know,
3 she would always continuously tell me. I mean, but
4 every time, it was the same thing.
5 I mean I was never -- I mean, I was never
6 mean to any of them. I never gave anybody attitude
7 about anything. But, I mean, she knows that. She
8 knows how I feel.
9 Q I think what I hear you saying is that she
10 knows how you feel, and you made it clear to her from
11 the start, that you were not a victim?
12
13 because
14
15 me
16
17
18 Q Do you think that's what she was trying to
19 do, is try to convince you to change your attitude as
20 to how you felt?
21 A In a way, yes.
22 Q Is there anything else that we need to
23 discuss that we haven't talked about?
24 A No, I think that's mostly it.
25 Q I appreciate your courtesies once again for
A Yeah, I mean, she pretty much, does it -
that's what she has to do. She has to continue
to tell me. And, you know, in a way, try to convince
that I am a victim.
I just let her say what's she's going to say,
and, then, you know, okay, goodbye.
Ph. 561.682.0905 - Fax. 561.682.1771
Lake's' Blvd:; Suit0"500 -'West-Palrn 'Betth; FL 33401- •
•-•
HOUSE OVERSIGHT 012559
nsor & Associates
-:--ZoparEing Dr 1".-rene.,c•cip.ti lo*, • . - .
Page 15
1 seeing me one more time, and doing this voluntarily.
2 And, thanks so much for making yourself
3 available today.
4 A No problem.
5 Q That will do it -- actually, one more time.
6 Brittany, let me say one more time:
7 Everything you've told me here today is the
8 absolute truth, right?
9 A Yes.
10 Q I haven't tried to convince you to say one
11 thing, one way or the other, have I?
12 A No.
13 Q All right. That's it. Thank you very much.
14 (Thereupon, the sworn statement was
15 concluded at 6:22 p.m.)
16
17
18
19
20
21
22
23
24
25
Ph. 561.682.0905 - Fax. 561.682.1771
• " —1655 Pal'hi- B'each' Lake's Blvdr.,'Suite 500 -'West PaIrri BeathTFL 33401— ' ' '
HOUSE OVERSIGHT 012560
nsor & A5soaate5
- - mid TEPISC‘Tiri.1-1M5 ..... ,
-
Page 16
1 THE STATE OF FLORIDA
2 COUNTY OF PALM BEACH
3
4
5
6 I, the undersigned authority, certify that
7
personally appeared before me on March
8 26, 2008 and was duly sworn.
9
10
11 WITNESS my hand and office seal this 26TH day
12 of MARCH, 2008.
13
14
15
16
17
18
19
20
21
22
23
24
25
(.01A;L 6, if?4,40)
Maria C. Powers, Court Reporter
Notary Public - State of Florida
My Commission No. DD149010
My Commission Expires: 9/10/10
Ph. 561.682.0905 - Fax. 561.682.1771
-1655'Palim Beach Lakes''Blvd:"aiite500'-'We'st Palm Rack FL 33:401"-- •
HOUSE OVERSIGHT 012561
,
1 1
nor & Associate5
Page 17
1 CERTIFICATE
2
3 The State of Florida
County Of Palm Beach
4
5
6 I, MARIA C. POWERS, a Shorthand Reporter, State
of Florida at Large, do hereby certify that
7 was by me first duly sworn to testify
the whole truth; that I was authorized to and did
8 report said deposition in stenotype; and that the
foregoing pages, numbered from 1 to 17 inclusive, are a
9 true and correct transcription of my shorthand notes of
said deposition.
10
I further certify that said deposition
11 was taken at the time and place hereinabove set forth
and that the taking of said proceeding was commenced
12 and completed as hereinabove set out.
13 I further certify that I am not an
attorney or counsel of any of the parties, nor am I a
14 relative or employee of any attorney or counsel of
party connected with the action, nor am I financially
15 interested in the action.
16 The foregoing certification of this
transcript does not apply to any reproduction of the
17 same by any means, unless under the direct control
and/or direction of the certifying reporter.
18
IN WITNESS WHEREOF, I have hereunto set
19 my hand this 26TH day of MARCH, 2008.
20
21
22
Maria C. Powers, Notary Public
23 In and for the State of Florida
My Commission No. DD149010
24 My Commission Expires: 9/10
25
Ph. 561.682.0905 - Fax. 561.682.1771
• 1655 Pah' Beath" Lakes BlVd., Suite 500 West Palm Beath; 'FL33401 • •
HOUSE OVERSIGHT 012562
nsor Rft Associate5
--Repnrting 4:qui Tpinwriptipp.,
Page 18
Ph. 561.682.0905 - Fax. 561.682.1771
"'- 1655 Palm Beach' Lakes-BlVd."; Sult`500"--West Palrn Beach, FL 33401 • • '1
HOUSE OVERSIGHT 012563
- ,1
nsor &..A55ociates
our1 l'r;tri3c•ri•pti.tm, 1pc.: • r
Pace 19
'
• Ph. 561.682.0905 - Fax. 561.682.1771
1655-Palm' Beath 'Lakes Blvd., Suite 500 - West Palm'Beath; FL-33401- ' '
HOUSE OVERSIGHT 012564
,
nsor Cl A550ate5
•
,
Page 20
Ph. 561.682.0905 - Fax. 561.682.1771
''' • '" 1655'Palhl Beach 'LakeS 500'1'West 'PaIhrBeaCh,:FIL 33401
HOUSE OVERSIGHT 012565
TAB 16
HOUSE OVERSIGHT 012566
11/16/2006 16:31 FAX 5618021787
USAO IPPB FL ra 002
U.S. Department of Justice
United States- Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
November 16, 2006
VIA FACSIMILE
Lilly Ann Sanchez, Esq.
Fowler White Burnett
1395 Brickell Ave Fl 14
Miami Florida 33131-3300
Re: Jeffrey Epstein
Dear Ms. Sanchez:
Thank you for your letter and voicernail. I will plan to direct all correspondence to you
unless you provide other instructions. In turn, please direct all future communications with the
Office to my attention.
As I mentioned in my voicemail, Mr. Lewis stated that Mr. Epstein is willing to provide
documents and information that we deem necessary to the investigation. I would appreciate if you
would forward the documents and information listed below to my attention or, if you prefer, to
Special Agent E. Nesbitt Kuyrkendall, Federal Bureau of Investigation, 500 South Flagler Drive,
Suite 500, West Palm Beach, PL 33404. If you require a grand jury subpoena for any of the items,
please let me know_
1. Documentation related to the ownership of the property located at 358 Ell3rillo Way,
Palm Beach, Florida, including the purchase agreement and any mortgages, liens, or
other encumbrances.
2. Documentation related to the ownership of Gulfstream Aircraft N909JE, Model
01159B, and Boeing Aircraft N908JE, Model 727-31, including purchase
information, lease agreements, liens or other encumbrances, and payments for
maintenance and storage.
3. All documents and information provided to the Palm Beach County State Attorney's
Office in connection with its investigation of Mr. Epstein.
4. Bank information, account numbers, bank statements and billing statements for any
bank accounts and/or credit cards used by Mr. Epstein (or any of his employees) to
pay for Mr. Epstein's personal expenses, from January 1, 20(04 to the present.
00269
HOUSE OVERSIGHT 012567
11/16/2006 1631 FAX 5618021787 USA() WPB FL
LIMAINSANCHEZ,ESQ.
NovErva3ER.16, 2006
PAGE 2 OF 3
ZI003
5. Information and billing statements for any "land lines," cellular telephones,
Blackberry units, e-mail addresses, webpages, or the like for Mr. Epstein and all of
his personal assistants (including but not limited to and
from January 1, 2004 to the present.
6. The computers, hard drives, CPUs, and any other computer media (ineluding CD-
ROMs, DVDs, floppy disks, flash drives, etc.) removed from 358 El Brillo Way,
Palm Beach, Florida prior to the execution of the search warrant at that premises in
October 2005.
7. All calendars, diaries, and address books kept by Mr. Epstein and all of his personal
assistants from January 1, 2004 to the present, including electronic calendars and
address books, whether stored on computer, PDA, or cellular telephone.
8. For persons in his employ at any time from January 1, 2004 to the present,
employment and/or separation agreements between Mr. Epstein (or his company)
and his personal assistants, airplane pilots, personal chefs, and for anyone who
worked at 358 El 13riLlo Way, Palm Beach, Florida.
9. The names and contact information of all persons who performed "massage services"
for Mr. Epstein at 358 El Brillo Way, Palm Beach, Florida or at his residences in
New Albany, Ohio, Little St. James, U.S.V.I., and New York, NY; and
documentation of payments made to or gifts given to any such persons.
10. Wage and earnings statements and other tax documents for all individuals referenced
in items (8) and (9), supra.
11. Mr. Epstein's tax returns for 2004 and 2005.
12. From January 1, 2004, to the present, flight manifests and passenger lists for travel
via Gulfstream Aircraft N909.1E, Model G1159B and Boeing Aircraft N908JE,
Model 727-31 (to the extent not already provided).
13. Documentation regarding any other interstate or international travel undertaken by
Mr. Epstein from January 1, 2004, to the present, including but not limited to
airplane tickets, ear rental records, and hotel receipts.
After I have a chnce to review the documents, I will contact you to set up a time to
interview Mr. Epstein.
00270
HOUSE OVERSIGHT 012568
11/16/2006 16:32 FAX 5618021787 USAO WPB FL
LILLY ANN SANCH R7, ESQ.
Nova/mm.16, 2006
PAGE 3 OF 3
e 004
Thank you for your assistance with this matter, and I look forward to working with you and
Mr. Lefcourt.
By:
Sincerely,
R. Alexander Acosta
United States Attorney
A. Marie Villafaiia
Assistant United States Attorney
00271
HOUSE OVERSIGHT 012569
TAB 17
HOUSE OVERSIGHT 012570
JUN-20-20e? 11:18
H)-44g (KCV. 6-2-90
FBI WEST PALM BEACH RA P.01
FBI FACSIMILE
COVER SHEET
PRECEDENCE
El Immediate
ID Priority
El Routine
To: William Riley
CLASSIFICATION
0 Top Secret Time Transmitted: _________________________
El Secret Sender's Initials: jrr
0 Confidential Number of Pages:  5
I:1 Sensitive (including cover sheet)
iili Unclassified
Name of Office
Facsimile Number: 954-905-4922
Attn:
Name
From: FBI
Room Telephone
Name of Office
Subject  Service of Federal Grand Jury Subpoenas
Date: 06/20/2007
Special Handling Instructions: _______________________________________________________________________________________________________________
Originator's NalIle: SA Jason Richards  Telephone: 561-833-7517
Originator's Facsimile Number: 5 61 - 8 33 - 7 979
Approved: _____________________________________________
Brief Description of Corarnunipation Faxed:  Two subpoenas: 1) William Riley arid. 2)
Custodian of Records, Riley Kiraly
WARNING
Information attached to the cover sheet is U.S. Government Property. If you arc not the intended recipient of this
information, disclosure, reproduction, distribution, or use of this information is prohibited (I S.USC, § 641). Please notify the
originator or the local FBI Office immediately to arrange for proper disposition.
HOUSE OVERSIGHT 012571
JUN-20-2007 11:18
FBI WEST PALM BEACH RR P.02
United States District Court
SOUIHERN DISTRICT OF FLORIDA
TO: Custodian of Records
Riley Kiraly
Comnoercial Center of Miatni
6155 NW 167th Street E-26
Miami, FL 33015
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
Fog 07-103(WPB)No. OLY-64
SUBPOENA FOR:
PERSON 12d DOCUMENTS OR OBJECVI
YOU ARE HEREBY COMMANDED to appear and testifyhefore the Grand Jury ofthe United States District
Court at the place, date and time specified below.
PLACE:
United States District Courthouse
701 Clematis Street
West Palm Beach, Florida 33401
ROOM:
Grand Jury Room
DATE AND TIME:
July 10, 2007
l00 pm*
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
TEE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT
*Please coordinate your compliance with this subpoena and confirm the date, time, and location of your
appearance 'with WA Nesbitt Kuyrkendall, Federal Bureau of Investigation-, Telephone: (561) S22-5946.
ThiS subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
on behalf of the court.
This subpoena is issued upon application
of the U'led States of America
•11":aet Applicable, cram "none:
Name, Address and Phone Number of Assistant U.S, Attorney
Alan Marie C. Villafst3,a, Assistant IJ_S..Attorney
500 So. Australian Avenue, Suite 400
West Palm Beach, FL 33401-6235
Tel: (561) 820-8711 x3047.
Pax: (561) 802-1787
Tdla used in Enn of AIM 10
FORM ORD-227
JAN.86
HOUSE OVERSIGHT 012572
JUN-20-2007 11:19
FBI WEST PALM BERCH RA P.03
ATTACHMENT A
SUBPOENA TO PAUL A. LAVERY
1. All computer equipment and electronic storage media removed from the
residence located at 358 El Brill° Way, Palm Beach, Florida, including but not
limited to central processing units ("CPUs"), laptop computers, keyboards,
printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms,
DVDs, floppy diskettes, digital cameras, and memory cards.
2. MI comptiter equipment and electronic storage media that currently belongs
to, or has ever belonged to, Jeffrey Epstein, including but not limited to central
processing units ("CPUs"), laptop computers, keyboards, printers, modems,
routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy
diskettes, digital cameras, and memory cards.
3. All documents and information related to the nature of the relationship
between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein,
including, but not limited to, retainer agreements; employment agreements;
billing statements (whether submitted directly to Mr. Epstein or to a third party
for reimbursement); records of the dates when services were performed and
the hours worked; telephone logs or records of dates of communications with
Mr. Epstein (or with a third party on Mr. Epstein's behalf); appointment
calendars/datebooks and the like (whether in hard copy or electronic form) for
any period when work was performed on behalf of Mr. Epstein or when any
communication was had with Mr. Epstein (or with a third party on Mr.
Epstein's behalf); and records of fee arrangements and payments received for
work performed on Mr, Epstein's behalf,
HOUSE OVERSIGHT 012573
JUN-20-2007 11:19
FBI WEST PALM BEACH RA
P.
United States District Court
SOUTHERN DISTRICT OF FLORIDA
' TO: William Riley
Riley Kiraly
ComMercial Center of Miami
6135 NW 167th Street E-26
Miami, FL 33015
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
FOJ 07-103(WPB)/No. OLY.-63
SUBPOENA FOR:
PERSON Fl DOCUMENTS OR OBSECiTS1
X
YOU ARE PIEREBY COMMANDED to appear and testify before the Qrand July ofthe United States District
Court at the place, date and time specified below.
P LACL.:
United States District Courthouse
701 Clematis Street
West Palm Beach, Florida 33401
ROOM:
Grand Jury Room
DATE AND TIME: •
July 10, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the following docinnent(s) or object(s):
I tit. DOCUMENTS AND OBJECTS LISTED ON ATTACHNIENT A.
*Please coordinate your compliance with this subpoena and confirm the date time and location of your
appearance with S/A Nesbitt Kuyritendall, Federal Bureau of Investigation, Telephone: (61) 822-5946.
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
on behalf of the court.
This subpoena is issued upon application
of the United States of America
+Irmo( applicabk, owe "none."
Name. Address and Phone Number of Assistant U.S. Attorney
Ann Marie C. Villafalla, Assistant U.S. Attorney
500 Se. Australian Avenue, Suite 400
West Palm Beach, EL 33401_6235
Tel: (561) 8204711 x3047
Fax: (561) 302-1787
ToreI IgAl;)1111
FORM QR.I>2.27
JA1416
HOUSE OVERSIGHT 012574
JUN-20-2007 1119
FBI WEST PALM BEACH RA P.05
ATTACHMENT A
SUBPOENA TO PAUL A. LAVERY
1. All computer equipment and electronic storage media removed from the
residence located at 358 El Brillo Way, Palm Beach, Florida, including but not
limited to central processing units ("CPUs"), laptop computers, keyboards,
printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms,
DVDs, floppy diskettes, digital cameras, and memory cards.
2. All computer equipment and electronic storage media that currently belongs
to, or has ever belonged to, Jeffrey Epstein, including but not limited to central
processing units ("CPUs"), laptop computers, keyboards, printers, modems,
routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy
diskettes, digital cameras, and memory cards.
3. All documents and information related to the nature of the relationship
between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein,
including, but not limited to, retainer agreements; employment agreements;
billing statements (whether submitted directly to Mr. Epstein or to a third party
for reimbursement); records of the dates when services were performed and
the hours worked; telephone logs or records of dates of communications with
Mr. Epstein (or with a third party on Mr. Epstein's behalf); appointment
calendars/datebooks and the like (whether in hard copy or electronic form) for
any period when work was performed on behalf of Mr. Epstein or when any
communication was had with Mr. Epstein (or with a third party on Mr.
Epstein's behalf); and records of fee arrangements and payments received for
work performed on Mr. Epstein's behalf
TOTAL P.05
HOUSE OVERSIGHT 012575
TAB 18
HOUSE OVERSIGHT 012576
U.S. Department of Justice
United States Attorney
Southern District of Florida
DELIVERY BY ELECTRONIC MAIL
Jay P. Lefkowitz, Esq.
Kirkland & Ellis LLP
Citigroup Center
153 East 53rd Street
New York, New York 10022-4675
Re: Jeffrey Epstein
Dear Jay:
500 S. Australian Ave, Ste 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
December 13, 2007
I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non-
Prosecution Agreement, which will be addressed by the United States Attorney, but the time has
come for me to respond to the ever-increasing attacks on my role in the investigation and
negotiations.
It is an understatement to say that I am surprised by your allegations regarding my role
because I thought that we had worked very well together in resolving this dispute. I also am
surprised because I feel that I bent over backwards to keep in mind the effect that the agreement
would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the
agreement. For example, I brought to your attention that one potential plea could result in no gain
time for your client; I corrected one of your calculations of the Sentencing Guidelines that would
have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the
Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired;
and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the
press. Importantly, I continued to work with you in a professional manner even after I learned that
you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded
that solicitation of minors to engage in prostitution was a registrable offense and that you would
"fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is
clear that neither you nor your client ever intended to abide by the terms of the agreement that he
signed, I have never alleged misconduct on your part.
The first allegation that you raise is that I "assiduously" hid from you the fact that Bert
Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz.
HOUSE OVERSIGHT 012577
JAY P. LEFKOWITZ, ESQ.
DECEMBER 13, 2007
PAGE 2 OF 5
I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people
whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about
this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and
I spoke about this case, he did not know about my relationship with his friend. You suggest that I
should have explicitly informed you that one of the referrals came from my "boyfriend" rather than
simply a "friend," which is the term I used, but it is not my nature to discuss my personal
relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted
to find someone whom I could trust with safeguarding the victims' best interests in the face of
intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz
was that person.
One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend.
This is patently untrue and neither my boyfriend nor I would have received any financial benefit
from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's
actions (as described below), he expressed a willingness to handle the case pro bono, with no
financial benefit even to himself. Furthermore, you were given several other options to choose from,
including the Podhurst firm, which was later selected by Judge Davis. You rejected those other
options.
You also allege that I improperly disclosed information about the case to Mr. Ocariz. I
provided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment
to help him decide whether the case was something he and his firm would be willing to undertake.
I did not provide Mr. Ocariz with facts related to the investigation because they were confidential
and instead recommended that he "Google" Mr. Epstein's name for background information. When
Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I
forwarded those questions to you, and you raised objections for the first time. I did not share any
further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you
concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's
decision to use a Special Master to make the selection and told him that the Office had made contact
with Judge Davis. We have had no further contact since then and I have never had contact with
Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his
decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to
try to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution
Agreement vested the Office with the exclusive right to select the attorney representative.
Another reason for my surprise about your allegations regarding misconduct related to the
Section 2255 litigation is your earlier desire to have me perform the role of "facilitator" to convince
the victims that the lawyer representative was selected by the Office to represent their interests alone
and that the out-of-court settlement of their claims was in their best interests. You now state that
doing the same things that you had asked me to do earlier is improper meddling in civil litigation.
Much of your letter reiterates the challenges to Detective Recarey's investigation that have
HOUSE OVERSIGHT 012578
JAY P. LEFKOWITZ, ESQ.
DECEMBER 13, 2007
PAGE 3 OF 5
already been submitted to the Office on several occasions and you suggest that I have kept that
information from those who reviewed the proposed indictment package. Contrary to your
suggestion, those submissions were attached to and incorporated in the proposed indictment
package, so your suggestion that I tried to hide something from the reviewers is false. I also take
issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and
witness statements that you like and we must accept as false those parts that you do not like. You
and your co-counsel also impressed upon me from the beginning the need to undertake an
independent investigation. It seems inappropriate now to complain because our independent
investigation uncovered facts that are unfavorable to your client.
You complain that I "forced" your client and the State Attorney's Office to proceed on
charges that they do not believe in, yet you do not want our Office to inform the State Attorney's
Office of facts that support the additional charge nor do you want any of the victims of that charge
to contact Ms. Belohlavek or the Court. Ms. Belohlavek's opinion may change if she knows the full
scope of your client's actions. You and I spent several weeks trying to identify and put together a
plea to federal charges that your client was willing to accept. Yet your letter now accuses me of
"manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child
privacy laws. When Mr. Lourie told you that those charges would "embarrass the Office," he meant
that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a
statement with which I agree.
I hope that you understand how your accusations that I imposed "ultimatums" and "forced"
you and your client to agree to unconscionable contract terms cannot square with the true facts of
this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed
for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to
the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you
mention in your letter, I —a simple line AUSA — handled the primary negotiations for the Office, and
conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled
and experienced practitioners. As you put it, your group has a "combined 250 years experience" to
my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcaut,
whose experience speaks for itself. You and I spent hours negotiating the terms, including when to
use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly
went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at
various times. In any and all plea negotiations the defendant understands that his options are to
plead or to continue with the investigation and proceed to trial. Those were the same options that
were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein
chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel.
You also make much of the fact that the names of the victims were not released to Mr.
Epstein prior to signing the Agreement. You never asked for such a term. During an earlier
meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and
I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that
HOUSE OVERSIGHT 012579
JAY P. LEFKOWITZ, ESQ.
DECEMBER 13, 2007
PAGE 4 OF 5
issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was
not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the
agents and I have vetted the list of victims more than once. In one instance, we decided to remove
a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided
that the link to a payment was insufficient to call it "prostitution." I have always remained open to
a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is
simply unfounded.
Your last set of allegations relates to the investigation of the matter. For instance, you claim
that some of the victims were informed of their right to collect damages prior to a thorough
investigation of their allegations against Mr. Epstein. This also is false. None of the victims was
informed of the right to sue under Section 2255 prior to the investigation of the claims. Three
victims were notified shortly after the signing of the Non-Prosecution Agreement of the general
terms of that Agreement. You raised objections to any victim notification, and no further
notifications were done. Throughout this process you have seen that I have prepared this case as
though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior
to concluding the matter by plea or trial would only undermine my case. If my reassurances are
insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of
the integrity of the investigation.'
'There are numerous other unfounded allegations in your letter about document demands,
the money laundering investigation, contacting potential witnesses, speaking with the press, and the
like. For the most part, these allegations have been raised and disproven earlier and need not be
readdressed. However, with respect to the subpoena served upon the private investigator, contrary
to your assertion, and as your co-counsel has already been told, I did consult with the Justice
Department prior to issuing the subpoena and I was told that because I was not subpoenaing an
attorney's office or an office physically located within an attorney's office, and because the business
did private investigation work for individuals (rather than working exclusively for Mr. Black), I
could issue a grand jury subpoena in the normal course, which is what I did. I also did not
"threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their
grand jury coordinator makes perfectly clear.
With regard to your allegation of my filing the Palm Beach Police Department's probable
cause affidavit "with the court knowing that the public could access it," I do not know to what you
are referring. All documents related to the grand jury investigation have been filed under seal, and
the Palm Beach Police Department's probable cause affidavit has never been filed with the Court.
If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response
to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one
should have access to it except the Court and myself. Those documents are still in the Court file
only because you have violated one of the terms of the Agreement by failing to "withdraw
[Epstein's] pending motion to intervene and to quash certain grand jury subpoenas."
HOUSE OVERSIGHT 012580
JAY P. LEFKOWITZ, ESQ.
DECEMBER 13, 2007
PAGE 5 OF 5
With respect to Ms. Miller, I contacted her attorney - who was paid for by Mr. Epstein and
was directed by counsel for Mr. Epstein to demand immunity - and asked only whether he still
represented Ms. Miller and if he wanted me to send the victim notification letter to him. He asked
what the letter would say and I told him that the letter would be forthcoming in about a week and
that I could not provide him with the terms. With respect to Ms. Miller's status as a victim, you
again want us to accept as true only facts that are beneficial to your client and to reject as false
anything detrimental to him. Ms. Miller made a number of statements that are contradicted by
documentary evidence and a review of her recorded statement shows her lack of credibility with
respect to a number of statements. Based upon all of the evidence collected, Ms. Miller is classified
as a victim as defined by statute. Of course, that does not mean that Ms. Miller considers herself
a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified
victims will not seek damages, but that does not negate their legal status as victims.
I hope that you now understand that your accusations against myself and the agents are
unfounded. In the future, I recommend that you address your accusations to me so that I can correct
any misunderstandings before you make false allegations to others in the Department. I hope that
we can move forward with a professional resolution of this matter, whether that be by your client's
adherence to the contract that he signed, or by virtue of a trial.
Sincerely,
R. Alexander Acosta
United States Attorney
By: s/A. Marie Villafana
A. Marie Villafaria
Assistant United States Attorney
cc: R. Alexander Acosta, U.S. Attorney
Jeffrey Sloman, First Assistant U.S. Attorney
You also accuse me of " broaden [ing] the scope of the investigation without any foundation
for doing so by adding charges of money laundering and violations of a money transmitting business
to the investigation." Again, I consulted with the Justice Department's Money Laundering Section
about my analysis before expanding that scope. The duty attorney agreed with my analysis.
HOUSE OVERSIGHT 012581
TAB 19
HOUSE OVERSIGHT 012582
vaA0110 (Rev. 04/07) Subpoena In Tcstify Before Grand Jury
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
TO:
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
FGJ 07-10-3(WPB)-Tues. No. OLY-85/1
SUBPOENA FOR:
ft PERSON lEr DOCUMENT(S) OR OBJECT(S)
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District
Court at the place, date, and time specified below.
-pLiNicg
United States District Court
701 Clematis Street
West Palm Beach, Florida 33401
.COLRTR 00 M • "
Grand Jury Room
tiATEAND TIME
7/1/2008 10:30 am
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):.
ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA.
0 Please see additional Information on ret,-,t
This subpoena shall remain in elf
behalf of the court.
(By) Deputy clod(
This subpoena is issued on application
of the- CA a'
• Irnol applicable. enla "none".
p.rikbythe couk or by an-officet acting on.
NAME; ADDRESS' AND PHONE NUMBER or ASSISTANT US. ATTORNEY
Ann Marie C. Villafarla, Assistant U.S. Attorney
500 South Australian Avenue, Suite 400
West Palm Beach, Florida 33401-6235
Tel: (561) 820-8711, ext 3047
HOUSE OVERSIGHT 012583
ATTACHMENT TO GRAND JURY SUBPOENA OLY-85/1
ADDRESSED TO
PLEASE BRING THE FOLLOWING DOCUMENTS, ITEMS, AND INFORMATION WITH YOU
TO YOUR GRAND JURY APPEARANCE:
1. Any and all notes, letters, cards, gifts, payments, photographs, or other items that you
have received from Jeffrey Epstein,__________________
Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein.
2. Any and all photographs, whether printed or digital, of Jeffrey Epstein,
Lesley Groff, Ghislaine Maxwell, and/or any
other employee or associate of Jeffrey Epstein.
3. Any and all c-mails, instant messages, chats, text messages, voicemails or telephone
messages that you have sent to and/or received from Jeffrey Epstein,
Lesley Groff, Ghislaine Maxwell, and/or any other
employee or associate of Jeffrey Epstein.
4. A list of all telephone numbers (cellular and "land line"), e-mail addresses, screen
names, addresses, and any other contact information that you have for the following persons during
the period of January 1, 2003 to the present:
a. yourself;
b. Jeffrey Epstein;
C.
d.
e.
f.
g. Lesley Groff;
h. Ghislaine Maxwell;
i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine
Maxwell;
j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine
Maxwell;
k. any person(s) who communicated with you to arrange appointments to meet
with Jeffrey Epstein and/or Ghislaine Maxwell.
5. Any billing statements for telephone service (cellular and "land line") for any
telephone you used during the period of January 1, 2003 to the present.
HOUSE OVERSIGHT 012584
TAB 20
HOUSE OVERSIGHT 012585
CONFIDENTIAL PLEA NEGOTIATIONS
TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT
• Epstein pleads guilty (not nob o contendere) to an Information filed by the
Palm Beach County State Attorney's Office charging him with:
(a) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4);
(b) solicitation of minors to engage in prostitution, in violation of Fl. Stat.
796.03; and
(c) engaging in sexual activity with minors at least sixteen years of age, in
violation of Fl. Stat. 794.05.
• Epstein and the State Attorney's Office make a joint, binding
recommendation that Epstein serve at least two years in prison without any
opportu
•
nity loi withholding acjudtcition ir sentencing, arid v 1
 agrees to waive all challenges to the information filed by the State
and the right to appeal.
• Epstein agrees that, if any of the victims identified in the federal
investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest
the jurisdiction of the U.S. District Court for the Southern District of
Florida over his person and the subject matter. Epstein will not contest that
the identified victims are persons who, while minors, were victims of
violations of Title 18, United States Code, Sections(s) 2422 and/or 2423.
• After Epstein enters his state court plea and is sentenced, the FBI and the
U.S. Attorney's Office will close their investigations into violations of 18
U.S.C. §§ 1591, 2422, and 2423.
HOUSE OVERSIGHT 012586
FEDERAL SENTENCING GUIDELIN'ES CALCULATION
(Using1NOvernher 1, 2004 Guidelines Manual):
aôh count of §4 101, 24n(b) and 2423(b):
Base Oftense Level under 761; 3 24
CiffensOmAwd::zexmltOtitadt:
20.
Counts do not4i!..OWS:0-.005.1.0-vels...fOr.more than 5 .Ittiltai pursuantto..31DIA.
Offense Level 3.1
Apply Repeat and D•angerous S Qx Offender against Minors enhanoetnent 2.:t 4B1.5
Total Offense Level 36
Asturning,criminalliisfory, Category 1, advisory guideline range is Y88 - 25 months with
lifetime. superViaed-relead,
HOUSE OVERSIGHT 012587
TAB 21
HOUSE OVERSIGHT 012588
IN RE:
INVESTIGATION OF
JEFFREY EPSTEIN
NON-PROSECUTION AGREEMENT
IT APPEARING that the City of Palm Beach Police Department and the State
Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter,
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
Epstein (hereinafter "Epstein");
IT APPEARING that the State Attorney's Office has charged Epstein by indictment
with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
IT APPEARING that the United States Attorney's Office and the Federal Bureau of
Investigation have conducted their own investigation into Epstein's background and any
offenses that may have been committed by Epstein against the United States from in or
around 2001 through in or around September 2007, including:
(1) knowingly and willfully conspiring with others known and unknown to
commit an offense against the United States, that is, to use a facility or means
of interstate or foreign commerce to knowingly persuade, induce, or entice
minor females to engage in prostitution, in violation of Title 18, United States
Code, Section 2422(b); all in violation of Title 18, United States Code, Section
371;
(2) knowingly and willfully conspiring with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18,
United States Code, Section 2423(b); all in violation of Title 18, United States
Code, Section 2423(e);
(3)
using a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females to engage in prostitution; in
violation of Title 18, United States Code, Sections 2422(b) and 2;
(4) traveling in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defmed in 18 U.S.C. § 2423(f), with minor females; in violation
Page 1 of 7
HOUSE OVERSIGHT 012589
of Title 18, United States Code, Section 2423(b); and
(5)
knowingly, in and affecting interstate and foreign commerce, recruiting,
enticing, and obtaining by any means a person, knowing that the person had
not attained the age of 18 years and would be caused to engage in a
commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
18, United States Code, Sections 1591(a)(1) and 2; and
IT APPEARING that Epstein seeks to resolve globally his state and federal criminal
liability and Epstein understands and acknowledges that, in exchange for the benefits
provided by this agreement, he agrees to comply with its terms, including undertaking certain
actions with the State Attorney's Office;
IT APPEARING, after an investigation of the offenses and Epstein's background by
both State and Federal law enforcement agencies, and after due consultation with the State
Attorney's Office, that the interests of the United States, the State of Florida, and the
Defendant will be served by the following procedure;
THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for
the Southern District of Florida, prosecution in this District for these offenses shall be
deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the
following conditions and the requirements of this Agreement set forth below.
If the United States Attorney should determine, based on reliable evidence, that,
during the period of the Agreement, Epstein willfully violated any of the conditions of this
Agreement, then the United States Attorney may, within ninety (90) days following the
expiration of the term of home confinement discussed below, provide Epstein with timely
notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its
prosecution on any offense within sixty (60) days' of giving notice of the violation. Any
notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the
United States learning of facts which may provide a basis for a determination of a breach of
the Agreement.
After timely fulfilling all the terms and conditions of the Agreement, no prosecution
for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have
been the subject of the joint investigation by the Federal Bureau of Investigation and the
United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury
investigation will be instituted in this District, and the charges against Epstein if any, will be
dismissed.
Page 2 of 7
HOUSE OVERSIGHT 012590
Terms of the Agreement:
1. Epstein shall plead guilty (not nob contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
one (1) count of solicitation of prostitution, in violation of Fl. Stat. §
796.07. In addition, Epstein shall plead guilty to an Information filed
by the State Attorney's Office charging Epstein with an offense that
requires him to register as a sex offender, that is, the .solicitation of
'mum 0 9-iigne m..prpstg-t#1,444 in violation of Florida Statutes Section
796.03;
2. Epstein shall make a binding recommendation that the Court impose a
thirty (30) month sentence to be divided as follows:
(a) Epstein shall be sentenced to consecutive terms of twelve (12)
months, and six (6) months in c'iintv 'ail for all charges, without
any opportumt for withholding idjudication!..6ii0
without rO.ation on community controJ in lieu•of
(b)
Epstein shall be sentenced to a term of twelve (12) months of
community control consecutive to his two terms in county jail
as described in Term 2(a), supra.
3. This agreement is contingent upon a Judge of the 15th Judicial Circuit
accepting and executing the sentence agreed upon between the State
Attorney's Office and Epstein, the details of which are set forth in this
agreement.
4. The terms contained in paragraphs 1 and 2, supra, do not foreclose
Epstein and the State Attorney's Office from agreeing to recommend
any additional charge(s) or any additional term(s) of probation and/or
incarceration.
5. Epstein shall waive all challenges to the Information tiled by the State
Attorney's Office and shall waive the right to appeal his conviction and
sentence, except a sentence that exceeds what is set forth in paragraph
(2), supra.
6. Epstein shall provide to the U.S. Attorney's Office copies of all
Page 3 of 7
HOUSE OVERSIGHT 012591
proposed agreements with the State Attorney's Office prior to entering
into those agreements.
'7. The TJnited States shall provide Epstein's attorneys with a list of
individuals whom it has identified as victims, as defmed in 1:$J:T.S.C.:
:2255. afterEpstein has signed this auppmenheensentenced.
Upon the execution of this agreement, the United States, in consultation
with and subject to the good faith approval of Epstein's counsel, .shall
k0::gtis:tOini! Epstein's counsel may contact the identified individuals
through that representative.
8. If any of the individuals referred to in paragraph (7), supra, elects to
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the
jurisdiction of the United States District Court for the Southern District
pfFlorida,oyer.4*,peyson and/or the subject matter, and Epstein
individualup to an amount as, agreed to htWe the identified 1.:
Epstein, so long as the identified individual elects to proceed
exclusively under 18 U.S.C. § 2255, and agrees to waive any other
claim for damages, whether pursuant to state, federal, or common law.
Notwithstanding this waiver, as to those individuals whose names
appear on the list provided by the United States, Epstein's signature on
this agreement, his waivers and failures to contest liability and such
damages in any suit are not to be construed as an admission of any
criminal or civil liability.
9. Epstein's signature on this agreement also is not to be construed as an
admission of civil or criminal liability or a waiver of any jurisdictional
or other defense as to any person whose name does not appear on the
list provided by the United States.
10. Except as to those individuals who elect to proceed exclusively under
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
signature on this agreement, nor its terms, nor any resulting waivers or
settlements by Epstein are to be construed as admissions or evidence of
civil or criminal liability or a waiver of any jurisdictional or other
defense as to any person, whether or not her name appears on the list
provided by the United States.
11. Epstein shall use his best efforts to enter his guilty plea and be
Page 4 of 7
HOUSE OVERSIGHT 012592
sentenced not later than October 26, 2007. The United States has no
objection to Epstein self-reporting to begin serving his sentence not
later than January 4, 2008.
12. Epstein agrees that he will not be afforded any benefits with respect to
gain time, other than the rights, opportunities, and benefits as any other
inmate, including but not limited to, eligibility for gain time credit
based on standard rules and regulations that apply in the State of
Florida. At the United States' request, Epstein agrees to provide an
accounting of the gain time he earned during his period of
incarceration.
13. The parties anticipate that this agreement will not be made part of any
public record. If the United States receives a Freedom of Information
Act request or any compulsory process commanding the disclosure of
the agreement, it will provide notice to Epstein before making that
disclosure.
Epstein understands that the United States Attorney has no authority to require the
State Attorney's Office. to abide by any terms of this agreement.„
-Iiiti!AW4Nigii#06*iiiMitg*WHaii4a104:Attorne
"
best efforts to ensure compliance with these procedures which cinpI
understandsstein  tha
9.,00 and to use his
44cP;*(01 he ncccssary
0.00 Epstein also understands that it is.:
efforts to IPPYMPe.the. Judge of the 15th Judicial Circuit to acce
.
recommendation,regarding.the sentence to be imposed, and understands that the *NM: todo
•ation
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-conspirators of Epstein, including but not limited to
Lesley Groff, or______________________ Further, upon execution of this
agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held
in abeyance unless and until the defendant violates any term of this agreement. The
defendant likewise agrees to withdraw his pending motion to intervene and to quash certain.
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
requested by or directly related to the grand jury subpoenas that have been issued, and
including certain computer equipment, inviolate until all of the terms of this agreement have
been satisfied. Upon the successful completion of the terms of this agreement, all
outstanding grand jury subpoenas shall be deemed withdrawn.
Page 5 of 7
HOUSE OVERSIGHT 012593
By signing this agreement, Epstein asserts and certifies that each of these terms is
material to this agreement and is supported by independent consideration and that a breach
of any one of these conditions allows the United States to elect to terminate the agreement
and to investigate and prosecute Epstein and any other individual or entity for any and all
federal offenses.
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
the Sixth Amendment to the Constitution of the United States provides that in all criminal
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court
may dismiss an indictment, information, or complaint for unnecessary delay in presenting
a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
hereby requests that the United States Attorney forthe Southern District of Florida defer such
prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
deemed to be a necessary delay at his own request, and he hereby waives any defense to such
prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of months equal to the period between the signing of this
agreement and the breach of this agreement as to those offenses that were the subject of the
grand jury's investigation. Epstein further asserts and certifies that he understands that the
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees
and consents that, if a prosecution against him is instituted for any offense that was the
subject of the grand jury's investigation, it may be by way of an Information signed and filed
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
to any such offense.
//I
///
///
Page 6 of 7
HOUSE OVERSIGHT 012594
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:_______________ By:
Dated:  77a,
Dated:
Dated:
A. MARIE VILLAFARA
ASSISTANT U.S. ATTORNEY
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
HOUSE OVERSIGHT 012595
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
Dated:________________ By:
A. MARIE VILLAFARA
ASSISTANT U.S. ATTORNEY
Dated:
Dated:
Dated:
JEFFREY EPSTEIN',
RALD EFCOUR ESQ.
COUNSEL TO JEFFREY EPSTEIN
LILLY ANN SANCHEZ, ESQ.
ATTORNEY FOR JEFFREY EPSTEIN
Page 7 of 7
HOUSE OVERSIGHT 012596
By signing this agreement, Epstein asserts and certifies that the above has been read
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them.
R. ALEXANDER ACOSTA
UNI1Ell STATES ATTORNEY
Dated:_______________ By:
A. MARIE VILLAFANA
ASSISTANT U.S. ATTORNEY
Dated:
JEFFREY EPSTEIN
Dated:
GERALD LEFCOURT, ESQ.
COUNSEL TO JEFFREY EPSTEIN
Dated: q--cA1J0.?"--
Z, ESQ.
ATTORNEY FOR JEk FREY EPSTEIN
Page 7 of 7
HOUSE OVERSIGHT 012597
TAB 22
HOUSE OVERSIGHT 012598
08/31/2007 13:03 FAX 5618021787
USA0 WFB FL
Q002
US_ Department of Justice
United States Attorney
Southern District of Florida
500 4outh Australian Ave., Suite 400
Tfesr Palm Redd, FL 33401
(561) 6264711
August 31, 2007
DELIVERY BY FACSIMILE
Ms.
In care of Bruce Lyons, Esq.
Lyons and Sanders
600 Northeast 3rd Avenue
Fort Lauderdale; FL 33304
Re: Grand Jury Investigation—Confidential
Dear
This letter is an invitation for you to testify before a federal Grand Jury, and is
supplied in order to provide helpful background information about the Grand Jury. The
Grand Jury consists of from sixteen to twenty-three persons from the Southern District of
Florida. It is their responsibility to inquire into federal crimes which may have been
committed in this District.
As a Grand Jury witness you will be asked to testify and answer questions under oath,
and to produce records and documents. Only the members of the Grand Jury, attorneys for
the United States and a stenographer- are permitted in the Grand Jury roorn while you testify..
. The U.S. Department of Justice encourages prosecutors to notify an individual in
appropriate cases that he or she is a target of a grand jury investigation. Accordingly, you
are hereby notified that you are a target of a federal grand jury investigation in the Southern
District of Florida concerning suspected violations of federal law, including but not limited
to, possible violations of Title 18, United- States Code, Sections 2, 371, 1512, 1591, 1952,
1956, 1960, 2421, 2422, and 2423.
You are advised that the destruction or alteration of any document required to be
produced:before the grand jury constitutes serious violation of federal law, including but.not
limited to Obstraction of justice.
A "target" is a person as to whom the prosecutors or the Grand Jury have substantial
HOUSE OVERSIGHT 012599
08/31/2607 13;04 FAX 5618021787 USA() WPB FL
Ms.
August 31, 2007
Page 2
epos
evidence linking him or her to the commission of a crime and who, in the judgment of the
prosecutors, is a putative defendant.
This letter constitutes an invitation to you to testify on your own behalf before the
grand jury about matters under investigation. Of course, you are not required to appear
before the grand jury. The decision whether to do so is a voluntary matter which is entirely
up to you. The grand jury, if in fact it learns of this opportunity afforded to you, will be
instructed not to draw any adverse inference from your failure to appear should you decide
not to accept this invitation. You mustfurther understand that should you decide to testify,
your testimony could be used against you if any criminal charges should be flied against you.
Should you decide to appear before the grand jury, you will have the same rights and
obligations as any non-immonized grand jury witness. Specifically,
You may refuse to answer any question if a truthful answer to the question
would tend to incriminate you.
You have the right to stop answering questions at any time.
Anything you say maybe used against you at the grand jury or in a subsequent
legal proceeding.
The grand jury will permit. you a reasonable opportunity to ..stop . outside the
grand jury room to consult with your attorney, if you so desire, at any point
during the testimony you give,
Please be further advised that the giving of false testimony before the grand jur3r will
subject -you to a prosecution for perjury in addition to the violations set forth above.
As a target of a grand jury investigation who has been asked to appear before the
grand jury, you may wish to retain the services of an attorney. If you =not afford the
services of independent counsel, the Court may be able to appoint Counsel to represent you.
If you would like the United States to ask the Court to appoint an attorney to represent you,
please contact the undersigned at 561 209-1047, The United States is investigating other
individuals, and you may be interested in cooperating with the United States against those
other targets. If you hire an attorney, or if the Court appoints one to represent you, that
counsel can contact me to discuss that possibility.
HOUSE OVERSIGHT 012600
08/31/2007 13:04 FAX 5618021787 USAO  WPB  FL
Ms.
August 31,2007
Page 3
0004
Please advise me whether you wish to testify before the grand jury by close of
business -Wednesday, September 12, 2007. If I do not receive notification from you or your
counsel by this date, I will assume that you do not wish to testify before the grand jury.
By:
Sincerely,
R. ALEXANDER ACOSTA
UNITED STATES ATTORNEY
A. Marie Villafana
Assistant United States Attorney.
HOUSE OVERSIGHT 012601
TAB 23
HOUSE OVERSIGHT 012602
08/16/2007 17:05 FAX 5618021787
IJSA0 WPB FL
•
U.S. Department of Justice
United States Attorney
Southern District of Florida
rip 002
SOO South Australian Ave., Suite 400
West Palm Beach, Ft 33401
(561) 820-8711 .
Facsimile: (561) 820-8777
August 16, 2007
VIA FACSIMILE
Gerald Lefcourt, Esq.
Gerald R Lefcourt, P.C.
148 East 78th Street
New York, NY 10021
Re: Subpoena to Custodian of Records-NES. LLC
Dear Mr. Lelbouri:
I write in response to your letter of July 18, 2007 regarding the grand jury subpoena issued
to the Custodian ofRecords for NES, LLC. Ihave attached an identical subpoena containing areturn
date of September 11, 2007, and subpoenas for two NES employees, Eric Gany and Harry Beller.
If you will not be representing Messrs. Gany and Beller, please let me know.
First, as I mentioned in my earlier correspondence, a properly executed declaration from. the
Custodian of Records is needed, and, if no documents responsive to a particular request exist, the
Custodian should certify that under penalty of perjury.
Second, you write that NES has no documents responsive to Requests 1 through 5. 'know
that NES has several credit card accounts for the benefit of the persons who manage Mr. Epstein's
properties, including Janusz Banasiak and Alfredo Rodriguez. I also know that NES regularly
receives money from an account that is used to pay expenses at 358 El Milo Way and also wires
money to that same account Those wire transfers fall within the time period called for by the
subpoena and number in the hundreds of thousands of dollars. IfNES does not maintain records of
its banking activities, then I would like to see a copy of its document retention policy, so I have
added that to the Attachment to the Subpoena.
Third, Mr. Manche's con:unent to you about potential money laundering charges related only
to a resolution ofthe case. In other words, if the sex offense case is resolved, the Office would close
its investigation into other areas as well The matter has not been, and it does not appear that it will
be, resolved so the money laundering investigation continues, and Request Number 6 will not be
withdrawn. The request is not overbroad and is stated with particularity, so please comply with the
request by the new deadline.
HOUSE OVERSIGHT 012603
68/16/2007 17:06  FAX $618021787
USA() WPB FL 0003
GERALD LEMUR% ESQ.
AuGUST 16,2007
PAGE 2 07 2
With respect to paragraph 7, the information provided regarding the pilots came from the
corporate records of Hypezion and TEGE, Inc., not NES. However, I have provided a shorter list in
the new subpoena attachment
I also have enclosed another certification for the Custodian of Records' signature.
Thank you again for your assistance.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
cc: E. Nesbitt Kuyrkendall, FBI (with enclosures)
A. Marie Villafafia
Assistant United States Attorney
HOUSE OVERSIGHT 012604
4/1642007 17:06 FAX 5618021787
US.A0 WPB FL tOO4
TO: Custodian of Records
NES, LLC
United States District Court
SOOTIMRNDISTRTCT OF FLORIDA
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
FGJ 07-103(WPB)/No. OLY-6,5/2
SUBPOENA FOR:
Fcl PERSON )M DOCUMENTS OR OBJECT[SI
YOU ARE HEREBY COMMANDED to wear a:ad testifybefore the Grand Jury ofthe United States District
Court at the place, date and lime specified below.
,
• PLACE'
United States District Courthouse
701 Clematis Street
West Palm Beaob, Florida 33401
ROM-
Grand Jury Room
DATE AND TIME:
September 11, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):
THE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT A.
*Please coordinate your compliance with this subpoena and confirm the date, time, and location of your
appearance with S/A Nesbitt Xnyrkendall, Federal Bureau of Investigation, Telephone: (561) 827-5946.
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
on behalf of the court.
plot
August 16, 2007
This subpoena is issued upon application
of &el/njied States of America
Name, Address and Phone Number of Assistant U.S. Attorney
Arm Marie C. Villaffia, Assistant U.S. Attorney
500 So. Australian Avemie, Suite 400
West Palm Beach, FL 33401-6235
Tel: (561) 820-8711 x3047
Fs= ($61) 802-1787
*it not applitable, ma "nom."
Tunh,i of A0110
FORM ORD-227
JAN.86
HOUSE OVERSIGHT 012605
08/16/2007 17:06  FAX 5618021787 USA° WPB FL 005
ATTACIEVIENT TO SUBPOENA OLY-65/2
YES, LLC
•
1. • For the period of January 1, 2003 to the present, all calendars, agendas, daily
diaries, or other records of appointments, travel, meetings and the lac, kept by or
on behalf of Jeffrey Epstein, Lesley 'Groff, and/or
____________________ This request includes information that is kept in physical
"hard copy" and/or electronic form, whether stored on a personal computer,
database server, cellular telephone, "Blacicberrj" unit, personal digital assistant
("PDA'') or other handheld electronic device, or in any other electronic form, and
all metadata included within the electronic/physical files.
2. For the period of January 1, 2003 to the present, all address books, contact lists, or
other records of names, telephone numbers, addresses, and/or e-mail addresses
kept by or on behalf of Jeffrey Epstein, Lesley Grog
and/or___________________ This request includes information that is kept in
physical "hard copy" and/or electronic form, whether stored on a personal
computer, database server, cellular telephone, "Blackberry" unit, personal digital
assistant ("PDA") or other handheld electronic device, or in any other electronic
form; and all metadata included within the electronic/physical files.
3. For the period of January 1, 2003 to the present, all e-mails, instant messages, text
messages, meeting invitations, and any other electronic Communication sent by
Jeffrey Epstein, Lesley Groff; and/or
to Jeffrey Epstein, Lesley Groff, and/or
This request includes information that is kept in physical
"hard copy" and/or electronic form, whether stored on a personal computer,
-database server, cellular telephone, "Blackberry" unit, personal digital assistant
("PDA") orother handheld electronic device, or in any other electronic form, and
all metadata included within the electronic/physical files.
4. For the period of January 1, 2003 to the present, all documents and information
referring or relating to the transfer of funds to or from any account owned by NES,
LLC to or from any bank account used for the maintenance of the property located
at 358 El Brill° Way, Palm Beach, Florida, or for the payment of any person
working at 358 El Brillo Way, Palm Beach, Florida.
Page 1 of 2
HOUSE OVERSIGHT 012606
. .08/16/2007 17:07  FAX 5618021787
U521.0 WPB FL Q006
5. For the period of January 1, 2003 to the present, all documents and information
referring or relating to the transfer of funds to or from any account owned by NES,
LLC to or from any bank account on which Janusz Banasiak and/or Alfredo
Rodriguez had or has check-writing authority and/or access to via debit/ATM card.
6. For the period of January 1, 2003 to the present, all documents and information
referring or relating to the transfer of fund to or from any account owned by NPS,
LLC to or from any account owned by JEGE, Inc., Jeffrey E. Epstein, Hyperion
Air, Inc., Financial Trust Co., New York Strategy Group, Inc., J. Epstein Virgin
Islands Foundations, Inc., and/or Epstein Interests.
7. For the period of January 1, 2003 to the present, the names of all employees and all
corporate directors, board members, and shareholders.
8. For the period of January 1, 2003 to the present, copies of all W-2s and/or 1099s
for the following persons: Jeffrey Epstein, Lesley Grog
Janusz Banasiak, Alfredo Rodriguez, Harry
Beller, and Erie T. Gany.
Any and all document retention and/or destruction policies_
•
Page 2 of 2
;
HOUSE OVERSIGHT 012607
O8/161Z007 17:07 FAX 5618021787
USA() WPB FL 0007
UNITED STATES DISTRICT COURT
SOO:0ERN DISTRICT OF FLORIDA
IN RE FEDERAL GRAND JURY SUBPOENA
OLY-65/2
ADDRESSED TO NES, .LLC
•-•- ••• •• • • •
CERTIFICATION REGARDING DOMESTIC RECORDS
OF REGULARLY CONDUCTED ACTIVITY
tb.e undersigted, ... -- declare that I am employed by
NES, LLC in the position of______________________________________ and, by reason ofmy position,
am authorized and qualified to make this declaration.
I. In my employment with NES, LLC, I am familiar with the business records it
maintains.
2. I certify that the records attached to this certification:
(a)
(b)
(c)
were made at or near the time of the occurrence of the matters set forth
therein, by or from information transmitted by, a person with knowledge of
those matters;
were kept in the course of regularly conducted business activity, and
were made by the regularly conducted activity as a regular practice.
" •
2. Among the records so maintained are the attached records itemized in Appendix A
(Document Inventory).
3. I further certify that the documents attached hereto are responsive to Grand Jury
Subpoena 65/2 served upon NES, LLC.
Page 1 of 2-
HOUSE OVERSIGHT 012608
08/16/2007 17:07 FAX 5618021787 USA0 WPB FL
-
:OW
4. I further certify that NES, LLC has no documents responsive to request number(s)
_____________. in Grand Jury Subpoena number 65g. [Fil1 in or strike out as appiopriate.]
Pursuant to 28 § 1746, I declare under penalty of pednry that the foregoing
information is true and correct
Executed this  .  day of, •
Awe cifeiectition:_________________________________________
Signature
Page 2.of -2
,
HOUSE OVERSIGHT 012609
not applicable, cater "nonC."
08/10/2007 17:07 FAX 5618021787.
tiSA0WPB FL ral 000
._ TO: HARRY BELLER
NFS, LLC
United States District Court
SOUTHERN DISTRICT OF FLORIDA
• SUBPOENA TO TESTIFY
BEFORE GRAND JURY
For 07-103(WPB)/No. OLY-75
SUBPOENA FOR:
n PERSON in DOCUMENTS OR OBJECT[S]
YOU ARE HEREBY COMMANDED to appear and testifybefore the *Grand Juryoftbe United States District
Court at the place, date and time specified below. •
_
-PLACE:
United States District Courthouse
• 701 Clematis Street
ROOM:
Grand Jury Room
West Palm Beach, Florida 33401 DATE AND TIME:
September 11, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you the following docuront(s) or object(s):
*Please coordinate your compliance with this subpoena_ and confirm the date, time, and location of your
appearance with S/A Nesbitt Knyrkendall, Federal Bureau of Investigation, Telephone: (561) 822-5946_
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
on behalf of the court.
This subpoena is issued upon application
of the United States of Amcrica.
Name, Address and Phone Number of Assistant U.S. Attorney
Ann Marie C. 'Meats", Assistant U.S. Attorney
500 So. Australian Avenue, Suite 400
West Palm Beach, FL 33401-6235
Tel: (561) 820-8711 x3047
1704 (50) 802-3787._ -
tvbraxdbirraiorAOIRt
' FORM ORO-227
JAN.86
HOUSE OVERSIGHT 012610
08/16/2007 17:07 FAX 5618021787
USA0 ll'FB FL on
• TO: ERIC G.ANY
NBS, LLC
•
United States District Court
SOUTIIERN DISTRICT OF FLORIDA
SUBPOENA TO TESTIFY
BEFORE GRAND JURY
PGJ 07-103(WPB)/No. OLY-76
SUBPOENA FOR:
Fic PERSON
DOCUMENTS OR OBJECT[S]
YOU An HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District
Court at the place, date and time specified below.
PLACE:
United States District Courthouse
701 Clematis Street
West Palm Beach, Florida 33401
42:0614!
Grand Jury Room
DATE AND TIME: .
September 11, 2007
1:00 pm*
YOU ARE ALSO COMMANDED to bring with you. the following document(s) or object(s):
*Please coordinate your compliance with this subpoena and confirm the date, time, and location of your
appearance with S/A Nesbitt Kuyrkendall, Federal Bureau of Investigation, Telephone: (561) 822-5946.
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting
on behalf of the court.
(BY)DEFUTYCLERK
DATE;
August:IC:2007
This subp_oenk is issued upon application
tittheYnif4Mat:e0gAlli:
*Ifnot upphcable. entex "none."
Name, Address and Phone Number of Assistant U.S. Attorucy
Alm Marie C. _______ Attorney
500 So. Australian Avenue, Suite 400
West Palm Beach, FL 33401-6235
Tel: ($61) 820-8711 x3047
Fax:4561) 802-1787
To Ix used Pt Eca afACH 10
FORM ORD-227
JAN.86
HOUSE OVERSIGHT 012611
-08/16/2007 17:05 FAX•5618021787 MAO WPB FL
US. Department of Justice
United States Attorney
Southern District of Florida
TO:
DATE: Auxusti6. 2007
FAX NO. 212-988-6192
PHONE NO. 212-737-0400
A. Marie Yillafana
500 S. Australian Ave, 4th Floor
West Palm ReackFlorida 33401
(560 820-8711
Facsimile (561) 820-8777
FACSIMILE COVER SHEET
Gerald Lefcourt, Esq..
# OF PAGES:____________________
RE: NES. LIGC
FROM: A. MARIE VILLA.FARA. Assistant U.S. Attorney
PHONE NO.  S61:2094047 •
COMMENTS:
;
HOUSE OVERSIGHT 012612
TAB 24
HOUSE OVERSIGHT 012613
09/19/2007 12:14 PM
"Villafana, Ann Marie C.
k(USAFLS\)"
To "Jay Lefkowitz"
cc
bcc
Subject RE: Meeting
Judge Johnson has duty next week.
Jay — [ hate to have to be firm about this, but we need to wrap this up by Monday. II 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: [ 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.
A. Marie Villafaria
Assistant U.S. Attorney
From: Jay Lefkowitz [mailto______________________
Sent: Wednesday, September 19, 2007 11:58 AM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: Meeting
We may want to meet monday and potentially continue to tues if necessary. Which mag is on duty?
-----Original Message-----
From: "Villafana, Ann Marie C. \(USAFLS\)"
Sent: 09/19/2007 11:51 AM AST
To: Jay Lefkowitz
Subject: Meeting
Barry is available Monday morning. Our most flexible West Palm Beach magistrate is on duty
on Monday, so, assuming we have signed documents by 1:30 or so, we should be able to get Mr.
Epstein arraigned on Monday. I doubt that we will be able to get everything finished up here,
get down to Miami, and try to find a Miami mag by close of business on Monday.
A. Marie Villafana
Assistant U.S. Attorney
***********************************************************
HOUSE OVERSIGHT 012614
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
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
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 in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
***********************************************************
HOUSE OVERSIGHT 012615
TAB 25
HOUSE OVERSIGHT 012616
09/23/2007 08:04 PM
"Villafana, Ann Marie C.
To "Jay Lefkowitz"
cc
bcc
Subject RE: Revised agreement
1 is definitely under 18 still, and I think there is a second minor. The appointment of ififfl
ad !item is to provide you with a mechanism to make contact with the girls and to give
them the assistance of an independent attorney who represents them (as opposed to me, who
represents the government). If you are willing to provide the girls with independent counsel, at
Mr. Epstein's expense (and I get to pick the attorney), that is alright with me.
From: Jay Lefkowitz [mailto_________________
Sent: Sunday, September 23, 2007 6:55 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: Revised agreement
Will do. "4,0 do you need a guardian ad litem at all? Are any of the 40 under 18 now?
-----Original Message-----
From: "Villafana, Ann Marie C. \(USAFLS\)'
Sent: 09/23/2007 06:52 PM AST
To: Jay Lefkowitz
Subject: Revised agreement
Hi Jay - Can you look at this? Especially paragraph 7. I think this covers the exclusive
remedy concern you had.
«070923 Epstein Non-Prosecution Agreement final.pdf»
***********************************************************
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
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
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 in error, please notify us immediately by
return e-mail or by e-mail to postmaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
***********************************************************
HOUSE OVERSIGHT 012617
TAB 26
HOUSE OVERSIGHT 012618
09/24/2007 01:27 PM
'Villafana, Ann Marie C.
To "Jay Lefkowilz"______________________________________
CC "Martin Weinber" "Lourie,
Andrew" "Garcia, Rolando
\(USAFLS\)"
bcc
Subject RE: Epstein agreement as reviewed by the U.S. Attorney
-,711fig...:frieg§a§6:11at beerifefW6ided
Hi Jay — Sony for the delay. The U.S. Attorney had a last-minute concern, that I think I fixed it
is in the first "It Appearing" clause following the list of statutes potentially violated).
After you get the green light, let's discuss the potential representative. The person I am thinking
of has run a preliminaiy conflicts check and it looks alright.
Also, to address Mr. Epstein's concern regarding the list of names, I wanted to tell you that I
have compiled a list of 34 confirmed minors. There are six others, whose names we already
have, who need to be interviewed by the FBI to confirm whether they were 17 or 18 at the time
of their activity with Mr. Epstein. Once those interviews are completed, I can finalize the list of
identified victims, which I will put in a formal document that I will maintain until the time of
Mr. Epstein's sentencing.
Assuming that this agreement is fine, please execute at least three copies, and send one to me by
fax and the rest by FedEx. I will execute and send the copies back.
Thank you.
A. Marie Villafalia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
HOUSE OVERSIGHT 012619
From:Jay Lefkowitz____________________________________
Sent: Monday, September 24, 2007 11:46 AM
To: Villafana, Ann Marie C. (USAFLS)
Cc: Martin Weinberg; Lourie, Andrew
Subject: Re: Epstein agreement as reviewed by the U.S. Attorney
Marie - Here are what I hope are final edits to the agreement. I will call in 15 min.
thanks -- Jay
"Villafana, Ann Marie C.
VUSAFLS\)"
09/24/2007 10:13 AM
To "Jay Lefkowitz" •
cc
Subje Epstein agreement as reviewed by the U.S.
ct Attorney
Hi Jay — Here is the agreement with Alex's edits. Thank you.
«070924 Epstein Non-Prosecution Agreement w Acosta edits v2.pdf»
A. Marie Villafalia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
HOUSE OVERSIGHT 012620
D070924 Final Epstein Non-Prosecution Agreement.pdf
HOUSE OVERSIGHT 012621
TAB 27
HOUSE OVERSIGHT 012622
"Villafana, Ann Marie C. To
\(USAFLS1)"
09/24/2007 04:34 PM
cc
bcc
Subject
RE: Do you have a signed copy?
Thank you, Jay. I have forwarded your message only to Alex, Andy, and Rolando. I don't
anticipate it going any further than that. When I receive the originals, I will sign and return one
copy to you. The other will be placed in the case file, which will be kept confidential since it also
contains identifying information about the girls.
When we reach an agreement about the attorney representative for the girls, we can discuss
what I can tell him and the girls about the agreement. I know that Andy promised Chief Reiter
an update when a resolution was achieved. (Something I wouldn't have promised in light of what
happened last year.) Rolando is calling, but Rolando knows not to tell Chief Reiter about the
money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that
has been agreed to. Rolando also is telling Chief Reiter not to disclose the outcome to anyone.
From: Jay Lefkowitz ________________________
Sent: Monday, September 24, 2007 4:06 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: Do you have a signed copy?
Marie - Please do whatever you can to keep this from becoming public.
thanks -- Jay
"Villafana, Ann Marie C. 1(USAFLS\)"
09/24/2007 04:04 PM
To..Jay Lefkowitz"
cc
SubjectDo you have a signed copy?
Fli Jay — Sorry to be a bother, but do you have a copy that at least contains Mr. Epstein's
signature? I need to pass it along to the powers that be. Thanks.
HOUSE OVERSIGHT 012623
TAB 28
HOUSE OVERSIGHT 012624
"Villafana, Ann Marie C.
(USAFLS\)"
09/26/2007 11:01 AM
To "Jay Lefkowitz"
cc
bcc
Subject RE: Other attorneys
essag a ee o
Hi Jay — Can you give me a call at his morning? I am meeting with the agents
and want to give them their marching orders regarding what they can tell the girls.
Also, please remove Babbitt and Searcy from the list. There is too great a chance of an
appearance of impropriety with Babbitt and I received a bad report about Searcy last night.
Thank you.
A. Marie Pilaf-a-14a
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From: Villafana, Ann Marie C. (USAFLS)
Sent: Tuesday, September 25, 2007 8:37 PM
To: 'Jay Lefkowitz'
Subject: Other attorneys
Hi Jay — These four people were recommended. I have not contacted them to find out what their
rates are. All are very active in the plaintiffs' bar in the West Palm area. Ted Babbitt would be
my first choice of these four but I think he is conflicted out because one of his partners is
married to an AUSA here. Stuart Grossman is probably my second choice.
Ted Babbitt -- http://www.babbitt-johnson.com/tbabbitt.html
Stuart Grossman -- http://www.grossmanandroth.com/sgrossman.htm
Chris Searcy -- http://vvww.searcylaw.com/CHRISTIANDSEARCY/tabid/935/default.aspx
Lake Lytal, Jr. -- http://www.lytalreiter.com/index.php?page id=37
HOUSE OVERSIGHT 012625
Talk to Jack Goldberger about this group. They are all very good personal injury lawyers, but I
have concerns about whether there would be an inherent tension because they may feel that
THEY might make more money (and get a lot more press coverage) if they proceed outside the
terms of the plea agreement. (Sorry — I just have a bias against plaintiffs' attorneys.) One nice
thing about Bert is that he is in Miami where there has been almost no coverage of this case.
Just so you know, I have never met Bert, but a good friend in our appellate section and one of the
district judges in Miami are good friends with him and recommended him.
Can you let me know tomorrow? I am going to be out for a while starting on Friday, and I
would like to get this underway before I leave.
Thank you.
A. Marie Villafacia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
HOUSE OVERSIGHT 012626
TAB 29
HOUSE OVERSIGHT 012627
10/05/2007 07:48 AM
"Villafana, Ann Marie C.
(USAFLS)"
To "Jay Lefkowitz"
cc
bcc
Subject RE: Proposed Letter to Special Master
WMPRWIr
EA*76-41.4gR,V'
Good morning, Jay. We need to resolve the attorney issue today. It has been
weeks since execution of the contract, and there is no need for further delay.
As far as the five attorney names that we will be providing, I propose Bert
Ocariz, Katherine Ezell at Podhurst Orseck, Stuart Grossman, Ed Rogers, and
Walter Cobath.
If you would like to use the same Special Master to resolve fees disputes as
well as to handle the selection of the attorney, I would recommend that we use
retired 11th Circuit Judge Joseph Hatchett instead of Judge Davis because of
Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but
one of the District Judges in Miami mentioned him as a good choice.)
I am available for a conference call between 9:00 and 10:00, and between 3:15
and 6:00. Please call me on my cell and let me know which of
those times works best for you.
Thank you.
From: Jay Lefkowitz
Sent: Wed 10/3/2007 4:26 PM
To: Villafana, Ann Marie C.. (USAFLS)
Subject: Re: Proposed Letter to Special Master
Marie - I, too, am interested in speed. But I really need to go over this and
then discuss with Jeffrey. So please do not send this to any Special Master
before we discuss the next steps.
Thanks -- Jay
"Villafana, Ann Marie C. (USAFLS)"
10/03/2007 04:24 PM
To
"Jay Lefkowitz"
cc
Subject
Proposed Letter to Special Master
HOUSE OVERSIGHT 012628
Hi Jay - To move things along, I also have enclosed the proposed text of a
letter to the Special Master.
«PROPOSED Letter to Special Master.pdf»
A. Marie Villafafia
Assistant U.S. Attorney
HOUSE OVERSIGHT 012629
TAB 30
HOUSE OVERSIGHT 012630
'Villafana, Ann Marie C. To
(USAFLS)"
09/27/2007 03:06 PM
cc
bcc
Subject RE: Conference Call with Bert Ocariz
,
15:ime§ageiba&beer.r:orwar.
Hi Jay — I already told Bert that there is no indictment and, as I mentioned, he doesn't really
need to/want to see the entire plea agreement, .just the relevant paragraphs so that he understands
what the scope of his representation will be. I think they would be happy knowing that their
hourly rate will be paid when it is billed. The concern is, if all 40 girls decide they want to sue,
they don't want to be in a situation where Mr. Epstein says this is getting too expensive, we won'
t pay any more attorneys' fees.
Two suggestions, that I haven't run past Bert, are:
1. Mr. Epstein signs a standard fee agreement, where one of his attorneys or
accountants who is not working on the damages litigation receives a monthly bill with
attorney's fees charged at an hourly rate and costs billed monthly. The bills will have
any privileged information redacted. If there is a dispute about a bill that cannot be
resolved, it will be submitted to a mediator for resolution.
2. If that is too open-ended for Mr. Epstein, do the hourly/monthly billing until Berl.
has had a chance to confer with all of the girls to determine how many want him to
represent them. Once it is known how many girls will be represented by Bert, and maybe
who those girls are, there can be a more educated discussion about estimated fees and
costs.
Just some food for thought. I will be out of the office tomorrow, but I will be reachable by cell
Phone. I will make sure Bert is available and confirm the time with you.
A. Marie Villafana
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
From: Jay Lefkowitz __________________________
Sent: Thursday, September 27, 2007 2:53 PM
To: Villafana, Ann Marie C. (USAFLS)
Subject: Re: Conference Call with Bert Ocariz
Marie - I will not be able to get back to you until tomorrow. However, some of the questions he raised cause me
HOUSE OVERSIGHT 012631
some serious concern.
1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)?
Certainly he should not get a copy of any indictment.
2. When will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the
civil case?
I don't think he should get the plea agreement either.
3. Is there any cap or other limitation on attorney's fees that the defendant will pay in the civil case?
I can't imagine he would be entitled to anything other than an hourly fee.
4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs?
In any event, I need to consider these issues carefully and I cannot agree to any of these issues before we speak. I
would suggest we plan on talking tomorrow at 12 pm if you are available.
Jay
----- Original Message-----
From: "Villafana, Ann Marie C. (USAFLS)"
Sent: 09/27/2007 10:51 AM AST
To: Jay Lefkowitz
Subject: Conference Call with Bert Ocariz
Hi Jay — Bert's firm has raised a number of good questions about how they are going to get paid
and setting up a procedure that avoids any conflict of interest with their clients. Are you around
today to do a conference call? Let me know what times work for you because Bert wants to get
their conflicts counsel on the call with us.
These are some of the questions he sent to me. I told Bert that as part of our agreement we (the
federal government) are not going to indict Mr. Epstein, but gave him an idea of the charges that
we had planned to bring as related to 18 USC 2255. With respect to question 2, do I have your
permission to send Bert just that section of the plea agreement that applies to the damages claims
(I would recommend sending paragraphs 7 through 10, or at least 7 and 8)? Can you talk with
your client about items 3 and 4? I envisioned Shook Hardy sending regular bills to you, with
any privileged information redacted, and being paid like every other client pays the bills.
1. Can we get a copy of the indictment (or can you tell me the nature of the crimes against the girls)?
2. When will it be possible to see the plea agreement so that we understand exactly what Epstein
concedes to in the civil case?
HOUSE OVERSIGHT 012632
3. Is there any cap or other limitation on attorneys fees that the defendant will pay in the civil case?
4. What is the contemplated procedure for, and timing of, the payment of attorney's fees and costs?
A. Marie Villafalia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
***********************************************************
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
Kirkland & Ellis LLP or Kirkland & Ellis International LLP.
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 in error, please notify us immediately by
return e-mail or by e-mail to postrnaster@kirkland.com, and
destroy this communication and all copies thereof,
including all attachments.
***********************************************************
HOUSE OVERSIGHT 012633
TAB 31
HOUSE OVERSIGHT 012634
ei 2005 The Florida Bar
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Jeffrey Marc Herman
Member in Good Standing Eligible to practice in Florida
ID Number: - 521647
Address: Herman & Mermelstein P A
18205 Biscayne Blvd Ste 2218
North Miami Beach, Florida
331602148
United States
Phone: 305.9312200
E-Mail: jherman@hermanlaw.com
County: Miami-Dade
Circuit: 11
Admitted: 12/26/1985
10-Year None
Discipline History
Firm:
erman Sloman & Mermelstein PA
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http://www.floridabar.orginames.nsf/All/EDE6C2013E4B06CB85256A8400091E55?Open.
Page 1 of 1
HOUSE OVERSIGHT 012635
TAB 32
HOUSE OVERSIGHT 012636
JANE DOE NO. 1, by and through
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,
Plaintiffs,
vs.
JEFFREY EPSTEIN,
Defendant.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO
08 80069
MI-MARRA
MAGISTRATE JUDGE
YOHNSON
FILED by D C
INTAKE -----
JAN 24 2008
DCLELARKRUITSE:
S.D. OF FLA. • FT. .L.AUb
INDisADTDoary
COMPLAINT
Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent
and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this
Complaint against Jeffrey Epstein, as follows:
Parties, Jurisdiction and. Venue
1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the
age of 18 years.
2. Jane Doe's Father brings this action individuallyand as parent and natural guardian of
Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida.
3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a
citizen and resident of the State of Florida.
4. This Complaint is brought under fictitious names to protect the identity of the Minor
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
HERMAN Et M ERM ELSTON P. A.
-1.
www.hermanlaw.com
HOUSE OVERSIGHT 012637
minor.
5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
6. This is an action for damages in excess of $50 million.
7. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
and (ii) is between citizens of different states.
8. This Court has venue of this action pursuant to 28 U.S.C. §I391(a) as a substantial
part of the events or omissions giving rise to the claim occurred in this District.
Factual Allegations
9. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
billionaires. He is himself a man of tremendous wealth, power and influence. 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.
10. 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
economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
them money. In or about 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one
of his victims.
11. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
12. An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach
HERMAN 8, MERMELSTEIN, P, A.
- 2 -
www.hermanlaw_com
HOUSE OVERSIGHT 012638
Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a
wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's
plan, Ms. Robson 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 directed Ms. Robson to bring
one or more underage girls to the residence. Ms. Robson, upon information and belief, generally
sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 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.
13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival. at
Epstein's mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein's assistant,
who gathered the girl' s personal information, including her name and telephone number. 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 photographs of nude women lining the stairway hall and in the
bedroom. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter
wearing only a towel. He would then remove his towel, lay down naked on the massage table, and
direct the girl to remove her clothes. He then would perform one or more Iewd, lascivious and
sexual acts, including masturbation and touching the girl's vagina with a vibrator.
14. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to
give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein's mansion
in Palm Beach. Jane was introduced. to Sarah Kellen, who led her up the flight of stairs to the room
with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He
HERMAN X...-. MERMEL.STEIN, P. A.
- 3 -
www.hermanlaw.com
HOUSE OVERSIGHT 012639
removed his towel, and laid down naked on the massage table. He dtalanded that Jane remove her
clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her
underwear. Epstein then sexually assaulted Jane.
15. After Epstein had completed the assault, he left the room. Jane was then able to get
dressed, leave the room and go back down the stairs. She then met Ms. Robson again who brought
Jane home. Jane was paid $300 by Epstein. Ms. Robson was p aid $200 by Epstein for bringing Jane
to him.
16. As a result of this encounter with Epstein, the 14-year old Jane experienced
confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral.
COUNT I
Sexual Assault
17, Plaintiff Jane Doe by and through her Father, as parent and natural guardian, repeats
and realleges paragraphs I through 16 above.
18. Epstein tortiously assaulted Jane Doe sexually in or about 2005.
19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which
recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane.
20. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
continue to suffer severe and permanent traumatic injuries, including mental, psychological and
emotional damages.
WHEREFORE, Plaintiff Jane Doe, by and through her Father, as parent and natural guardian,
demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages,
costs, and such other and further relief as this Court deems just and proper.
HERMAN 6, MERMELSTEIN, P. A.
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www.hermaniaw.com
HOUSE OVERSIGHT 012640
COUNT II
Intentional Infliction of Emotional Distress
21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane
Doe's Father and Jane Doe's Stepmother, individually, repeat and reallegeparagraphs 1 through 16
above.
22. Epstein's conduct was intentional or reckless.
23. Epstein's conduct was outrageous, going beyond all bounds of decency.
24. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to
her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that
his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's
parents.
25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe
mental anguish and pain.
WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural
guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey
Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
Court deems just and proper.
COUNT LEI
Loss of Parental Consortium
26. Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above.
27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's
Father, consisting of parental loss of comfort, companionship and society and healthcare costs
HERMAN & MERMELSTEIN, F'. A.
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www.hermanlaw.com
HOUSE OVERSIGHT 012641
associated with the treatment of J ane.
28. Jane Doe's Father experienced and will continue to experience great mental anguish,
pain and suffering from the time that Defendant's tortious conduct occurred.
WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium
damages, costs and such other and further relief as this Court deems proper.
JURY TRIAL DEMAND
Plaintiffs demand a jury trial in this action.
Dated: January c24, 2008 Respectfully submitted,
HERMAN & MERMELSTEIN, P. A.
- 6 -
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877
By:
Je M. Herman
j erman@herrnanlaw.com
Florida Bar No. 521647
Stuart S. IViermelstein
smermelstein@hermanlaw.com
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitz@hen-nanlaw.cora
www.hermanlaw.com
HOUSE OVERSIGHT 012642
HOUSE OVERSIGHT 012643
I of 6
Case 9:08-cv,80232-KAM Document 1 Entered on FLSD Docket 03/05/2008
JANE DOE NO. 3,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
1)
FIR2061  1 la  D.C.
ELECTRIC
March 5, 2008
STEVEN M. LARIMORE
CLERK U.S. 01ST. CT.
S. D. OF FLA. • MIAMI
CASE NO.:
08-CV-80232-Marra-Johnson
COMPLAINT
Plaintiff, Jane Doe No.3 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
Epstein, as follows:
Parties, Jurisdiction and Venue
1. Jane Doe is a citizen and resident of the State of Florida, and is sui juris.
2. This Complaint is brought under a fictitious name to protect the identity of the
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon her
when she was a minor.
3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
4. This is an action for damages in excess of $50 million.
5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
and (ii) is between citizens of different states.
6. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial
part of the events or omissions giving rise to the claim occurred in this District.
HERMAN & MERMELSTEIN, P. A.
- 1 -
www.hermaniaw.com
HOUSE OVERSIGHT 012644
Case 9:08-cv-80232-KAM Document 1 Entered on FLSD Docket 03/05/2008 Page 2 of 6
Factual Allegations
7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
billionaires. He is himself a man of ti-emendous wealth, power and influence. 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.
8. 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
economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
them money. In or about 2004-2005, Jane Doe, then 16 years old, fell into Epstein's trap and
became one of his victims.
9. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas.
10. An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach
Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a
wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's
plan, Ms. Robson 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 directed Ms. Robson to bring
one or more underage girls to the residence. Ms. Robson, upon information and belief, generally
sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 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
HERMAN & MERMELSTEIN, P. A.
2 of 6
- 2 -
www.hermanlaw.com
HOUSE OVERSIGHT 012645
Case 9:08-cv-80232-KAM Document 1 Entered on FLSD Docket 03/05/2008 Page 3 of 6
improper conduct were made. This was an important element of Epstein's plan.
11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
Epstein's mansion, the victim would be brought to the kitchen. She would then be led up a flight of
stairs to a bedroom that contained a massage table in addition to other furnishings. Once the girl was
alone in this room, Epstein would enter wearing only a towel to cover his private area. He then
would lay down on the massage table and perform one or more lewd, lascivious and sexual acts,
including masturbation and touching the girl sexually.
12. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to
give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein's mansion
in Palm Beach. Jane was led up the flight of stairs to the room with the massage table. She was
alone in the room when Epstein arrived wearing a towel to cover his private parts. He laid down on
the massage table, and sexually assaulted Jane Doe during the massage. In addition, Jeffrey Epstein
masturbated during the massage.
13. After Epstein had completed the assault, he left the room. Jane was then able to leave
the room and go back down the stairs. She then met Ms. Robson again who brought Jane home.
Jane was paid $200 by Epstein. Ms. Robson was also paid by Epstein for bringing Jane to him.
14. As a result of this encounter with Epstein, the 16-year old Jane experienced trauma,
shock, confusion, shame, humiliation and embarrassment.
COUNT I
Sexual Assault
15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
16. Epstein tortiously assaulted Jane Doe sexually in or about 2004-2005. Epstein's acts
were intentional, unlawful, offensive and harmful.
HERMAN St MERMELSTEIN, P. A.
3 of 6
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HOUSE OVERSIGHT 012646
Case 9:08,cv-80232-KAM Document 1 Entered on FLSD Docket 03/05/2008 Page 4 of 6
17. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
willfully and maliciously.
18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which
recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane.
19. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
continue to suffer severe and permanent traumatic injuries, including mental, psychological and
emotional damages.
WHEREFORE, Plaintiff Jane Doe, demands judgment against Defendant Jeffrey Epstein for
compensatory damages, punitive damages, costs, and such other and further relief as this Court
deems just and proper.
COUNT II
Intentional Infliction of Emotional Distress
20. Plaintiffs Jane Doe repeats and realleges paragraphs 1 through 14 above.
21. Epstein's conduct was intentional or reckless.
22. Epstein's conduct was outrageous, going beyond all bounds of decency.
23. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
reason to know that his intentional and outrageous conduct would cause emotional trauma and
damage to Jane Doe.
24. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe
has suffered and will continue to suffer severe mental anguish and pain.
WHEREFORE, Plaintiff Jane Doe demands judgment against Defendant Jeffrey Epstein for
compensatory damages, costs, punitive damages, and such other and further relief as this Court
HERMAN & MERMELSTEIN, P. A.
4 of 6
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HOUSE OVERSIGHT 012647
Case 9:08-cv-80232-KAM Document 1 Entered on FLSD Docket 03/05/2008 Page 5 of 6
deems just and proper.
JURY TRIAL DEMAND
Plaintiffs demand a jury trial in this action.
Dated: March 2008
HERMAN Eu. MERMELSTEIN, P. A.
-5-
5016
Respectfully submitted,
HERMAN 84. MERMELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877
By:
Jeffrey M. Herman
iherman@hermanlaw.com
Florida Bar No. 521647
Stuart S. Menrielstein
smermelsteinP,hermanlaw.com
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitz(@,hen-nanlaw.com
www.hermanlaw.com
HOUSE OVERSIGHT 012648
Case 9:08-cv-80232-KAM DocunGM111- CqVggcM1=14LED Docket 03/95/S008 Page 6 of
The JS-44 civil cover sheet and the Information contained herein neither replace nor supplement the filing, and service o p ea ng or other paps as required by law,
except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of
the Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
1(a) PLAINTIFFS DEFENDANTS
JANE DOE NO. 3, JEFFREY EPSTEIN
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
PALM BEACH COUNTY
(EXCEPT IN U.S. PLAINTIFF CASES)
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK
(IN U.S. PLAINTIFF CASES ONLY)
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)
Herman & Mermelstein, PA., 18205 Biscayne Blvd., Suite 2218, Miami,
FL 33160, (365) 931-2200
ATTORNEYS (IF KNOWN)
(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
II. BASIS OF JURISDICTION
(PLACE AN X ONE BOX ONLY)
o 1. U.S. Government
Plaintiff
0 2. U.S. Government
Defendant
III)
0 3. Federal Question
(U.S. Government Not a Party)
X 4. Diversity
(Indicate Citizenship of Parties in Item
CIOPCJI/ 90232 le-f9171-f)0 n*f.,
III. CITIZENSHIP OF PRINCIPAL PARTIES
(For Diversity Case Only)
PTF
Citizen of This State x 1
Citizen of Another State 0 2
DEF
CI 1
x 2
Citizen or Subject of a Foreign Country 0 3 0 3
PLACE AN X IN ONE BOX FOR PLAINTIFF
AND ONE FOR DEFENDANT PTF DEF
Incorporated of Principal Place of 0 4 0 4
Business in This State
Incorporated and Principal Place of 0 5 0 5
Business in Another State
Foreign Nation 0 6 0 6
IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.
DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.)
DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT
!Va. 5 days estimated (for both sides) to try entire case
V. NATURE OF SUIT
(PLACE AN X IN ONE BOX ONLY)
A CONTRACT   A TORTS   B FORFEITURE PENALTY   A BANKRUPTCY   A OTHER STATUS
0 110 Insurance CI 120Marine 0 130Miller Act 0 140Negoliable Instrument , a  tooRmv'Y ar °ver"Iffnen' & Enforcement of Judgment 0 15184edlcare Am 0 152Recoveryof Defaulted Student Loans (Excl. Veterans)B CI 153 Recovery of Oyerpayment of Veteran's Bane% El . 0 150Stockholderb Sults 0 1DOOther Contract 0 1135Contrast Product Llabildy ...   PERSONAL 0 310 Airplane 0 315 Airplane 0 320 AssaiAL 0330 Federal a 0 345 0 350 Moto 0 355 Motor X 360 Other   INJURY 0 382 Personal InjuntMed Malpractice Product Liability 0 365 Personal Injury-Product' Liablity Libel & Slander 0 368 Asbestos Personnel EMPiCl.re OabffitY !rimy Product Uabilky Product Uabilky PERSONAL PROPERTY ehIcle gide Product Llabilky 0 370 Other Fraud arsenal Injury 0 371 Truth in Lending B 0 380 Other Personnel Property Damage 0 385 Properly Damage Product Llabkly   0 810 Agriculture 0 820 Other Food & Om 0 825 Drug Related Seizure of Property 21 USC 881 0 630 Liquor LaVIS 0 840 R.Ft. & Truck 0 650 Aldine Rees 0 880 Occupational Safely/Health 0 800 Other   0 422 Appeal 28 USC 158 0 423 Withdrawal 28 USC 157   0 400 Status ReappotnIment 0 410 Antitrust 0 430 Banks and Banking 0 400 Commerce/ICC Ralesretc.13 0 460 Deportation o 470 Racketeer Influenced and Cermet OggenicaCons 0 810 Selective Service 0 850 Securities/Commodities/ Exchange CI 875 Customer Challenge 12USC3410 0 801 Agricultural Acts 0 Beg Economic Stater-393n Act 0 853 Envinonmental Matters 0 BIM EMMY/W=059AF, 0 695 Freedom of Inforrnalbn Act 0 BOO Appeal of Fee Determination Under Equal Access to Justice 0 050 Congitutionalkyof Stale Statutes 0 890 Myer Statutory Actions' • A Or 8 Declaratory relief and stale law claims for delemalion n 0
A PROPERTY RIGHTS
0 820 Copyrights 01130 Patent 0 IMO Trademark
B SOCIAL SECURITY
0851 H1A (139510 0 862 Black Lung (13231 0 863 DIWCJDNVW (405(9D CI 864 SS1D TAM XVI 0 665 RSI (405(g))
A REAL PROPERTY   A CIVIL RIGHTS   13 PRISONER PETITIONS   A LABOR
0 210 Land Condemnation 0 220 Foreclosure B CI 230 Rent Lease & Electment 0 240 Torts to Land 0 245 Tort Product Liability 0 MO All Other Real Property   CI 441 Voting 0 442Employment 0 443Housing/Accommodations 0 444 Welfare 0 4400thar CFA Rights   0 510Motions to Vacate Sentence Habeas Carew 0 5300eneral. 0 535130016 Penalty 0 540 Mandamus & Wet 0 550CMI Rights 'A or B   5710 Fat Labor Standards Act 0 720 Labor Management Relations B 0 730 Labor Management Reporting & Disclosure Act 0 740 Railway Labor Acl 0 700 Other Labor Litigation o 791 Employee Rel. Inc. Security Acts
A FEDERAL TAX SUITS
0 870 TOWS (U.S. PloinlIff or °denoted) 0 871 IRS-TI/ad Party 26 USC 7890 FILED bv
VI. ORIGIN
x 1. Original
0 2. Removed from 0 3. Remanded from 04. Refilled 0 6. Multidistrict Litigation
0 7. Appeal to District Judge from
Proceeding State Court Appellate Court 0 5. Transferred from another district
(Specify) Magistrate Judgment
VII. REQUESTED
IN COMPLAINT 0 UNDER F.R.C.P. 23
CHECK IF THIS IS A 0 CLASS ACTION
DEMAND $ 0 Check
complaint
JURY DEMAND:
MAR - 5 2008
cCitLA,,RK.E.N.C:. 0M ;Aar) njT.
5.0
Mal *qua Y S
0 NO
VIII. RELATED (See Instructions): (SEE ATTACHED)
CASE(S) IF ANY
Jane Doe 2 v. Jeffrey Epstein
JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-60119-MARRA-JOHNSON
DATE 3 - -0 t SIGNATURE OF ATTORNEY OF RECORD
UNITED STATES DISTRICT COURT
S/F 1-2
REV. 9194
6 of 6
FOR OFFICE USE ONLY: Receipt No.__________________ Amount
Date Paid: _______________________ M/ifp:__________________________
52/R6/1
HOUSE OVERSIGHT 012649
TAB 33
HOUSE OVERSIGHT 012650
Another suit alleges sex during massage
Page 1 of 2
PairalleachPost,com
Another suit alleges sex during massage
By i,ARRY KELLER
Palm Beach Post Staff Writer
Thursday, March 06, 2008
WEST PALM BEACH — Another woman filed a federal lawsuit against Jeffrey
Epstein on Wednesday, alleging that he turned a massage she gave him at his Palm
Beach mansion into a sexual episode when she was 16 years old.
Identified as "Jane Doe No. 3," she is seeking more than $50 million, the same as
two other "Jane Does" who filed similar lawsuits in the past six weeks. All three suits were filed by
Miami lawyer Jeffrey Herman.
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Herman subsequently withdrew the first
Jane Doe's lawsuit because of squabbling
by her parents over the litigation. The girl
may refile the suit after she turns 18 in May
and can make her own decisions, Herman
said.
More local news Other alleged victims also have contacted
him, Herman said. "I do anticipate more
Latest breaking news., photos and all of today's Post stories, cases," he said.
Share This Story
In the latest litigation, Jane Doe No. 3 alleges that she was recruited by a former college student, Haley
Robson, to give Epstein a massage for money at his waterfront home late in 2004 or early in 2005.
The lawsuit alleges that, while on the massage table, Epstein sexually touched Jane Doe No. 3, then
masturbated. She is suing on grounds of sexual assault and intentional infliction of emotional distress.
"She felt intimidated. She felt scared," Herman said. Jane Doe No. 3 made only the one visit to Epstein's
home, he said.
"It's just another copycat lawsuit filed by the same lawyer who appears less interested in the truth than in
grandstanding with these press conferences," said Jack Goldberger, one of Epstein's attorneys. "We now
have sworn testimony that girls lied about their age to Jeffrey Epstein, and they were careful in being
http://pahnbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Another+suit+alleg... 4/2/2008
HOUSE OVERSIGHT 012651
Another suit alleges sex during massage Page 2 of 2
convincing that they were over the age of 18."
Herman said Robson instructed Jane Doe No. 3, "When he asks how old you are, tell him 18 or 19 years
old." But he said it doesn't matter. "They were underage girls," Herman said. "They were sexually
assaulted."
In addition to the civil lawsuits, Epstein was indicted on a single count of felony solicitation of
prostitution in July 2006 after a lengthy Palm Beach Police Department investigation into his activities
with underage girls at his home. A resolution has been delayed continually. The case is on Monday's
court docket but is expected to be rescheduled once again.
"One of the reasons (Jane Doe No. 3) came forward is she is tired of waiting for justice," Herman said.
Find this article at:
http://www.palmbeachpost.com/localnews/content/local_news/epaper/2008/03/06/s3b_epstein_0306.html?
cxtype=rss&cxsvc=78xxcat=76
Check the box to include the list of links referenced in the article.
http://palmbeachpost.printthis.clickability.com/pt/cpt?action=cpt&title=Another-Fsuit+alleg... 4/2/2008
HOUSE OVERSIGHT 012652
TAB 34
HOUSE OVERSIGHT 012653
Jay,
Jay Lefkowitz/New
York/Kirkland-Ellis
Sent by: Kristin Andersen/New
York/Kirkland-Ellis
12/12/2007 04:20 PM
To Ami Sheth/New York/Kirkland-Ellis@K&E
cc Eugene Komel/New York/Kirkland-Ellis@K&E
bcc
Subject Fw: Epstein
— Forwarded by Kristin Andersen/New York/Kirkland-Ellis on 12/12/2007 04:19 PM
"Sloman, Jeff USAFLS"
11/27/2007 01:55 PM
To "Jay Lefkowitz"
cc "Acosta, Alex (USAFLS)"
Subject Epstein
Please accept my apologies for not getting back to you sooner but I was a little under the weather
yesterday. I hope that you enjoyed your Thanksgiving.
Regarding the issue of due diligence concerning Judge Davis' selection, I'd like to make a few
observations. First, Guy Lewis has known for some time that Judge Davis was making
reasonable efforts to secure Aaron Podhurst and Bob Josephsberg for this assignment. In fact,
when I told you of Judge Davis's selection during our meeting last Wednesday, November 2l4,
you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the
selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team
including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Professor Dershowitz who
said he knew Mr. Josephsberg from law school. Second, Podhurst and Josephsberg have
long-standing stellar reputations for their legal acumen and ethics. It's hard for me to imagine
how much more vetting needs to be done.
The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of
the anticipated upcoming events and their rights associated with the agreement entered into by
the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since
you were formally notified of the selection. I must insist that the vetting process come to an end.
Therefore, unless you provide me with a good faith objection to Judge Davis's selection by COB
tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give
me the go-ahead on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously
send you a draft of the letter. I intend to notify the victims by letter after COB Thursday,
November 29'1. Thanks,
Jeff
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TAB 35
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KIRKLAND &ELLIS LLP
AND AFFILIATED PARTNERSHIPS
777 South Figueroa Street
Los Angeles, California 90017
Kenneth W. Starr
To Call Writer Directly:
www.lcirkland.com
November 28, 2007
VIA FACSIMILE
Honorable Alice S. Fisher
Assistant Attorney General
Department of Justice
Criminal Division
950 Pennsylvania Avenue NW
Room 2107
Washington, DC 20530
Re: Jeffey Epstein
Dear Ms. Fisher:
Facsimile:
(213) 680-8500
I represent Jeffrey Epstein, who, as you may be aware, was the target of a dual
investigation by both state and federal authorities in Florida for acts relating to his interactions
with numerous young women. As you may also be aware, Mr. Epstein has entered into a
Deferred Prosecution Agreement (the "Agreement") with the United States Attorney's Office for
the Southern District of Florida (the "USAO") to resolve its criminal investigation of him. I run
writing to. request a meeting with you to discuss certain aspects of this case that I find especially
troublesome.
As part of the agreement Mr. Epstein was required to sign to avoid a federal indictment,
Mr. Epstein was required to waive jurisdiction and liability under 18 U.S.C. §2255 for the
settlement of monetary claims that might be made by it group of unidentified alleged victims
who will be identified by the USA() at some point in the future. Neither I, nor any of the other
defense lawyers involved in this matter, have ever heard of such a procedure. And as part of this
Agreement, Mr. Epstein is precluded from contesting liability as to civil lawsuits seeking
monetary compensation for damages brought by any of the identified individuals who elect to
settle their civil claims for the statutory minimum of either $50,000 (the amount set by Congress
as of the date of the occurrences) or $150,000 (the amount currently set by statute) or some other
agreed upon damage amount. We believe that the utilization of 18 U.S.C. § 2255 as a pre-
condition of criminal plea agreements or non-prosecution agreements is highly unusual and
requires careful consideration and additional guidance by your Office. We also believe that the
Chicago Hong Kong London Munich New York San Francisco Washington, D.C.
HOUSE OVERSIGHT 012656
IURKLAND 8.. ELLIS
Honorable Mice S. Fisher
November 28, 2007
Page 2
manner in which the USAO has interpreted the settlement process for these identified individuals
under the Agreement requires guidance. These areas are more fully detailed below.*
First. Federal criminal investigators and prosecutors should not be in the business
of promoting civil lawsuits as a condition precedent to entering non-prosecution or deferred
prosecution agreements. This is especially true where the vehicle for the financial settlement
under the Agreement requires payment in a lump sum without requiring proof of actual injury or
loss — federal authorities should therefore be particularly sensitive to avoid causing a prejudiced
and unfair result. 18 U.S.C. § 2255 is a civil statute implanted in the criminal code; in contrast to
all other criminal restitution statutes, § 2255 fails to correlate payments to specific injuries or
losses. Instead, the statute presumes that victims have sustained damages of at least a minimum
lump sum without regard to whether the complainants suffered actual medical, psychological or
other forms of individualized harm. We presume that it is for this reason that 18 U.S.C. § 2255
has never before been employed in this manner in connection with a non-prosecution or, as here,
a deferred prosecution agreement. In short, the USAO is operating in uncharted territory.
Second. 18 U.S.C. § 2255 creates the potential for compromising witness
testimony. Although generally the Government may promise or provide traditional consideration
to potential witnesses, employing a civil statute that promises a lump sum payment to potential
witnesses without proof of actual liability or damage provides an extraordinary incentive that is
incompatible with the truth-seeking functions of the criminal justice system. Guidelines or other
policy directives should be considered to control the extent to which witnesses are informed by
investigators about the availability of such financial windfalls. Additionally, an inquiry is
necessary in this specific case to assure that disclosures to potential witnesses did not undermine
the reliability of the results of the federal criminal investigation of Mr. Epstein.
Third. The USA() has provided no information as to the specific claims made by
each identified individual, nor were we provided the names or ages of those individuals or the
time-frame of the alleged conduct The USAO's reluctance to provide Mr. Epstein with any
information with respect to the allegations against him leaves wide open the opportunity for
misconduct by federal investigators. In addition, this information vacuum eliminates the ability
for Mr. Epstein and/or his agents to verify that the allegations at issue are grounded in real
evidence. Indeed, the requirement that a target of federal criminal prosecution agree to waive his
right to contest liability as to unnamed civil complainants creates at minimum an appearance of
injustice, both because of the obvious Due Process concerns of waiving rights without notice of
* In addition to the areas identified below, it was and remains our position that federal prosecution of this matter is
entirely inappropriate based on the prior application and legislative histories of the relevant federal statutes.
HOUSE OVERSIGHT 012657
KIRKLAND &ELLIS
Honorable Alice S. Fisher
November 28, 2007
Page 3
even the identity of the complainant(s) and because of the involvement of the federal criminal
justice system in civil settlements between private individuals.
Fourth. The USA() has improperly insisted that the chosen attorney
representative should be able to litigate the claims of individuals, which violates the terms of the
Agreement and deeply infringes upon the spirit and nature of the Agreement. Initially, for the
sake of expediting a settlement in this matter, we suggested that Mr. Epstein establish a
restitution fund specifically for the settlement of the identified individuals' civil claims and that
an impartial, independent representative be appointed to administer that fund. Notably, such a
restitution fund was created in a federal case, U.S. v. Boehm, Case No. 3:04CR00003 (D Alaska
2004). The federal prosecutors here rejected this idea, and they insisted that an attorney
representative, paid for by Mr. Epstein, be appointed. Yet, there was no suggestion at the time
that the attorney representative's duties included litigating claims on behalf of the identified
individuals. However, after the parties agreed to the appointment of an attorney representative,
the prosecutors announced that the criteria for choosing an appropriate attorney representative
now included that the individual be "a plaintiff's lawyer capable of handling multiple lawsuits
against high profile attorneys." This interpretation of the scope of the attorney representative's
role is far outside the common understanding that existed when we negotiated Mr. Epstein's
settlement with the USAO. Furthermore, we firmly believe that ethics rules preclude the
representative from litigating claims on behalf of the identified individuals.
In sum, we believe that the actions undertaken in this matter by the USA() with
respect to the 18 U.S.C. § 2255 provisions of the Agreement are highly unusual. We respectfully
request a meeting with you at your earliest convenience to discuss the important issues raised by
the USAO's conduct in this deeply policy-laden matter.
Sincerely,
id. Q2
Kenneth W. Starr
-
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11/28/07 WED 09:19 FAX 1 213 680 8500 KIRKLAND&ELLIS LLP
TRANSMISSION OK   ********************* *** T1 REPORT *** *********************
TX/RX NO   1638
CONNECTION TEL   912025149412
SUDADDRESS
CONNECTION ID
ST. TIME   11/28   09:17
USAGE T.   01'57
PGs.   4
RESULT   OK
Igj col
MRKLAND &ELLIS LLP
Fax Transmittal
777 South Figueroa Street
Los Angeles, Califomia 90017
Phone: (213) 680-8400
Falc (213) 680-8500
•
Please notify us immedlately•if any pages are not received. •
THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY
•
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IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR,
PLEASE NOTIFY US IMMEDIATELY AT:
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To: Company:
Hon. Alice S. Fisher Department of Justice
From: Date: Pagiesviecover:
Kenneth V/. Starr • November 28, 2007. 4
Message:
HOUSE OVERSIGHT 012659
TAB 36
HOUSE OVERSIGHT 012660
'Villafana, Ann Marie C.
(USAFLS)"
11/28/2007 04:46 PM
To
cc
bcc
Subject
is message has been replie
"Jay Leficowilz"
"Sloman, Jeff (USAFLS)"
"Acosta, Alex (USAFLS)"
Epstein: Victim Notification Letter
to nc
fetitiare(e.
Dear Jay:
Jeff asked that I forward the victim notification letter to you. It is attached.
Thank you.
«Victim Notification Ltr.pdf»
A. Marie Villafalia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
DVictim Notification Ltr.pdf
HOUSE OVERSIGHT 012661
7
U.S. Department of Justice
United States Attorney
Southern District of Florida
500 South Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Facsimile: (561) 820-8777
November 29, 2007
DELIVERY BY HAND
Miss
Re: Crime Victims' Rights — Notification of Resolution of Epstein Investigation
Dear Miss
Several months ago, I provided you with a letter notifying you of your rights as a victim
pursuant to the Justice for All Act of 2004 and other federal legislation, including:
(1) The right to be reasonably protected from the accused.
(2) The right to reasonable, accurate, and timely notice of any public court proceeding
involving the crime or of any release or escape of the accused.
(3) The right not to be excluded from any public court proceeding, unless the court
determines that your testimony may be materially altered if you are present for other
portions of a proceeding.
(4) The right to be reasonably heard at any public proceeding in the district court
involving release, plea, or sentencing.
(5) The reasonable right to confer with the attorney for the United States in the case.
(6) The right to full and timely restitution as provided in law.
(7) The right to proceedings free from unreasonable delay.
(8) The right to be treated with fairness and with respect for the victim's dignity and
privacy.
I am writing to inform you that the federal investigation of Jeffrey Epstein has been
completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing
the following terms.
•Mr....Ep.stein.agrees that he willTlead guilty to two state offenses, including the offense
of soliciting minors to engage in promtution, which will require him to register as a sexual predator
for the remainder of his life.
HOUSE OVERSIGHT 012662
MISS___________________
NOVEMBER 29, 2007
PAGE 2
Second, Mr. Epstein has agreed to make a binding recommendation of 18 months'
imprisonment to the state court judge who sentences him. Mr. Epstein will serve that sentence of
imprisonment at the Palm Beach County Jail.
Tj140 Mr. Epstein has agreed that he will not contest jurisdictien oi habibty4f you elect to
Awkofrom him because the United States has identified you as a minor victim of certain
federal offenses, including travel in interstate commerce to engage in prostitution with minors and
the use of facilities of interstate commerce to induce minors to engage in prostitution. To assist you
U.S.in making such a claim, the Attorney's Office has asked an independent Special Master to
select attorneys Those attorneys are iriciaNna.Ntrand Robeit ("Bob)
i'it4its#,Ogiwith the law firm of Podhurst Orseck, PA. They can be reached:at(305)358;280.Q.,
anticipate that someone from their law firm will be contacting you shortly. TiiiiigiffitiAdkikleitt
that you are not obligated to use these attorneys. In fact, you have the absolute right to select your
own attorney, so you can decide not to speak with Mssrs. Podhurst/ Tosefsberg at all, or you can
speak with them and decide at any time to use a different attorney. :Tfyou do decide to seek damages
from Mr. Epstein and you decide to use lessrs Podhurst/Josefsbeig asyour attorneys Mr Epstein
will be , attorney1eesi:incurred during the time spent trying to negotiate a
settlement. If you are unable to reach a settlement with Mr. Epstein, you and Mr. Josefsberg can
discuss how best to proceed.
As I mentioned above, as part of the resolution of the federal investigation, Mr. Epstein has
agreed to plead guilty to state charges. Mr. Epstein's change of plea and sentencing will occur on
December 14, 2007, at________a.m., before Judge Sandra K. McSorley, in Courtroom 11F at the Palm
Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida. Pursuant to
Florida Statutes Sections 960.001(1)(k) and 921.143 (1) you ale tigittagglitPiRabajda0
a statement under oath If you choose, you can submit a written statement under oath which will
be filed by the State Attorney's Office on your behalf. If you elect to prepare a written statement,
it should address the following:
the facts of the case and the extent of any harm, including social, psychological, or
physical harm, financial losses, loss of earnings directly or indirectly resulting from
the crime for which the defendant is being sentenced, and any matter relevant to an
appropriate disposition and sentence. Fl. Stat. 921.143(2).
You also are entitled to notification when Mr. Epstein is released from imprisonment at the
end of his prison term and/or if he is allowed to participate in a work release program. To receive
such notification, please provide the State Attorney's Office with the following information:
1. Your name
2. Your address
3. Your home, work, and/or cell phone numbers
HOUSE OVERSIGHT 012663
MISS___________________
NOVEMBER 29, 2007
PAGE 3
4. Your e-mail address
5. A notation of whether you would like to participate in the "VINE system," which
provides automated notification calls any time an inmate is moved. (To use this
system, your calls must go to you directly, not through a switchboard.)
Thank you for all of your help during the course of the investigation. If you have any
questions or concerns, please do not hesitate to contact me or Special Agent Nesbitt Kuyrkendall
at (561) 822-5946.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
A. Marie Villafaila
Assistant United States Attorney
cc: Special Agent Nesbitt Kuyrkendall, F.B.I.
Ms. Clearetha Wright, Victim-Witness Coordinator, U.S. Attorney's Office
HOUSE OVERSIGHT 012664
TAB 37
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"Sloman Jeff USAFLS' To
02/27/2008 09:45 PM
CC
bcc
Subject
"Oosterbaan, Andrew"
Fw: Epstein
Itory: :& This message has benforwarde
Sent from my BlackBerry Wireless Handheld
----- Original Message -----
From: Jeffrey Sloman
To: Sloman, Jeff (USAFLS)
Sent: Wed Feb 27 21:37:02 2008
Subject: Epstein
Jay,
You have renewed your request for certain information which this Office does
not generally make available in similar pre-indictment situations. After
carefully considering your request, I have decided, in my capacity as the
First Assistant U.S. Attorney, not to make an exception here.
Regarding the Landon Thomas matter, Mr. Thomas was given, pursuant to his
request, non-case specific information concerning specific federal statutes.
Regarding the offer to extend the current deadline of March 3, 2008 contained
in my February 25th email. That offer was based on counsel for Mr. Epstein
meeting with CEOS the week of March 3rd. You indicate that you are
unavailable. It is hard to imagine that some or all of the other attorneys
representing Mr. Epstein cannot serve this function. After all, Mr. Epstein is
also represented by Dean Kenneth Starr, Martin Weinberg, Roy Black, Gerald
Lefcourt, Harvard Professor Alan Dershowitz, Lily Ann Sanchez, and Guy Lewis.
That being said, the Southern District of Florida will only renew the offer to
extend the current deadline if you and the CEOS Section Chief mutually agree
on a timetable by close of business on Friday, February 29, 2008 to meet and
complete presentations no later than March 19, 2008. Given that CEOS is ready
to proceed immediately, this seems like more than ample time. As I indicated
in my previous email, if CEOS subsequently decides that a federal prosecution
should not be undertaken against Mr_ Epstein, this Office will close its
investigation. However, should CEOS disagree with Mr. Epstein's position, Mr.
Epstein shall have one week to abide by the terms and conditions of the
September 24, 2007 Agreement as amended by letter from United States Attorney
Acosta.
HOUSE OVERSIGHT 012666
Jeffrey H. Sloman
First Asst. US Attorney
Southern District of Florida
HOUSE OVERSIGHT 012667
TAB 38
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05/16/2008 11:16 FAX
05/16/08 FRI 11:08 FAX
U• NITED STATES DEPARTMENT OF JUSTICE
Criminal Division
Child Exploitation and Obscenity Section
1400 New York Avenue, NW
Suite 600
Washington, DC 20530-0001
• 20005
TO:
• OFFICE NUMBER:
• FAX NUMBER:
FROM:
Q001/006
VI001
• CEOS: (202) 514-5780
FAX: (202) 514-1793
• R. Alexander Acosta, Esq.
Tay T,efkowit.z, Esq.
• Alexandra Gelber.
DATE/TIME: May 16, 2008
OFFICE NUMBER: (202), 514-5780
NUMBER OF PAGES, F-3(CLUE>ING THIS SHEET: 5
SPECIAL INSTRUCTIONS:
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0 0 2 / 0 0 6
tJ 002
Child Eaploitarlon and 003-ceraty Section
Jay Lefkowitz, Esq.
Kirkland & Ellis LLP
Citigroup Center
153 E. 53" St.
New York, NY 10022-4611
U.S. Department of Justice
Criminal Division
Andrew G. Oosterbaan, Chief
1400 A'ew York Avenue, NW
Suite 600
Wialtingion, DC20530
(202) 514-5780 FAX: (202) 514-1793
May 15, 2008
Re: Investigation of Jeffery Epstein
Dear Mr. Lefkowitz:
Pursuant to your request and the request of U.S. Attorney R. Alexander Acosta, we have
independently evaluated certain issues raised in the investigation of Jeffrey Epstein to determine
whether a decision to prosecute Mr. Epstein for federal criminal violations would contradict
criminal enforcement policy interests. As part of our evaluation, we have reviewed letters
written on behalf of Mr. Epstein on February 1, 2007, June 25, 2007, July 6, 2007, March 28,
2008, April 8, 2008, April 28, 2008, and May 14, 2008, with their attachments. We have also
reviewed memos prepared by the U.S. Attorney's Office. As you will recall, we met with you
and other representatives of Mr. Epstein to further discuss your views on the propriety of a
federal prosecution. We have discussed the factual and legal issues you raise with the Criminal
Division's Appellate Section, and we consulted with the Office of Enforcement Operations
concerning the petite policy.
We are examining the narrow question as to whether there is a legitimate basis for the
U.S. Attorney's Office to proceed with a federal prosecution of Mr. Epstein. Ultimately, the
prosecutorial decision making authority within a U.S. Attorney's Office lies with the U.S.
Attorney. Therefore, to borrow a phrase from the case law, the question we soudit to answer
was whether U.S. Attorney Acosta would abuse his discretion if he authorized prosecution in this
case.
As you know, our review of this case is limited, both factually and legally. We have not
looked at the entire universe of facts in this case. It is not the role of the Criminal Division to re-
conduct a complete factual inquiry from scratch. Furthermore, we did not analyze any issues
concerning prosecution under federal statutes that do not pertain to child exploitation, such as the
money laundering statutes,
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0003/006
Q003
As was made clear at the outset, we did not review the facts, circumstances, or terms
included in the plea offer, nor any allegations that individuals involved in the investigation
engaged in misconduct. Despite that agreement, we note that your letters of April 8, April 28,
and May 14 focus in large part on accusations of investigative or prosecutorial misconduct. Not
only do allegations of prosecutorial misconduct fall outside the boundary of our agreed review,
they also fall outside the authority of the Criminal Division in the first instance. Simply, the
Criminal Division does not investigate or resolve allegations of professional misconduct by
federal prosecutors. For these reasons, we do not respond to the portion of those letters that
discuss alleged misconduct.
Based on our review of all of these materials, and after careful consideration of the issues,
we conclude that U.S. Attorney Acosta could properly use his discretion to authorize prosecution
in this case. We will briefly address each of the issues that you have raised.
Knowledge of age. Federal child exploitation statutes differ as to whether there must be
proof that the defendant was aware that the children were under the age of 18. However, even
for those statutes where knowledge of age is an element of the offense, it is possible to satisfy
that element with proof that the defendant was deliberately ignorant of facts which would suggest
that the person was a minor. For that reason, the fact that some of the individuals allegedly lied
to Mr. Epstein about their age is not dispositive of the issue. While there may be an open factual
issue as to Mr. Epstein's knowledge, we cannot say that it would be impossible to prove
knowledge of age for any such charges which require it. Therefore, Mr. Acosta could rightfully
conclude that this factual issue is best resolved by a jury.
Travel for the purpose. In the materials you prepared, you suggest that Mr. Epstein
should not be charged with violating 18 U.S.C. § 2423(1,) because his dominant purpose in going
to Florida was not to engage in illegal sexual activity, but rather to return to one of his residences.
While we fully understand your argument, we also find that the U.S. Attorney's office has a good
faith basis fully to develop the facts on this issue and brief the law to permit a court to decide
whether the law properly reaches such conduct. Mr. Acosta would not be abusing his discretion
if he decided to pursue such a course of action.
Intent to engage in the conduct at the time of travel, Based on our review of the facts of
this case, we respectfully disagree that there is no evidence concerning Mr. Epstein's intent when
he traveled, and when that intent was formed. Should Mr. Acosta elect to let the case proceed so
that a jury can resolve this factual issue, he would be within his discretion to do so.
Use of a facility or means of interstate or foreign commerce. Much of the materials you
have prepared and much of the meeting we had focused on 18 U.S.C. § 2422(b), specifically your
contention that Mr. Epstein did not use the phone to coerce anyone to engage in illegal sexual
activity.. We understand the issue you raise concerning the statutory interpretation. As before,
however, we cannot agree that there is no evidence that would support a charge under Section
2422(b), nor can we agree that there is no argument in support of the application of that statute to
this case. Finally, our assessment is that the application of that statute to these facts would not be
2
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g1004/006
0004
so novel as to implicate the so-called "clear statement rule," the Ex Post Facto clause, or the Due
Process clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case.
Absence of coercion. With respect to 18 § 1591, the alleged absence of the use of
force, fraud, or coercion is of no moment. The statute does not require the use of force, fraud,
and coercion against minors. Because of their age, a degree of coercion is presumed. In your
materials, you note that the statute requires that the minors must be "caused" to engage in a
commercial sex act, further arguing that the word "cause" suggests that a certain amount of
undue influence was used. We reject that interpretation, as it would read back into the offense an
element—coercion—that Congress has expressly excluded. We have successfully prosecuted
defendants for the commercial sexual exploitation of minors, even when the minors testified that
not only did they voluntarily engage in the commercial, sex acts, it was their idea to do so. As
such, Mr. Acosta could properly decide to pursue charges under Section 1591 even if there is no
evidence of coercion.
More broadly, a defendant's criminal liability does not hinge on his victim identifying as
having suffered at his hands. Therefore, a prosecution could proceed, should Mr. Acosta decide
to do so, even though some of the young women allegedly have said that they do not view
themselves as victims.
Witness credibility. As all prosecutors know, there are no perfect witnesses. Particularly
in cases involving exploited children, as one member of your defense team, Ms. Thacker, surely
knows from her work at CEOS, it is not uncommon for victim-witnesses to give conflicting
statements. The prosecutors are in the best position to assess the witness's credibility. Often, the
prosecutor may decide that the best approach is to present th.e witness, let defense counsel
explore the credibility problems on cross-examination, and let the jury resolve the issue. Mr.
Acosta would be within his authority to select that approach, especially when here there are
multiple, mutually-corroborating witnesses.
Contradictions and omissions in the search warrant application. We have carefully
reviewed the factual issues you raise concerning the search warrant application. For a search
warrant to be suppressed, however, the factual errors must be material, and the officers must not
have proceeded in good faith. Despite the numerous factual errors you describe, the U.S.
Attorney's Office could still plausibly argue that the mistakes—whether inadvertent or
intentional—were not material to the determination that probable cause existed for a search, and
that the search was in good faith in any event. As such, Mr. Acosta could properly elect to
defend the search warrant in court rather than forego prosecution.
Petite 1?olicy: After reviewing the petite policy and consulting with the Office of
Enforcement Operations ("0E0"), we conclude that the petite policy does not prohibit federal
prosecution in this case, According to the U.S. Attorney's Manual, the petite policy "applies
whenever there has been a prior state or federal prosecution resulting in an acquittal, a
conviction, including one resulting from a plea agreement, or a dismissal or other termination of
3
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IJ
UO05/006
005
the case on the merits after jeopardy has attached." USAIVI 9-2.031(C). Our understanding is
that the state case is still pending. As such, tehe procedural posture of the state case does not
implicate the petite policy.
We recognize that the petite policy could be triggered if the state case concluded after a
federal indictment was issued but prior to the commencement of any federal trial. Id. However,
the policy "does not apply ... where the [state] prosecution involved only a minor part of the
contemplated federal charges." USAM 9-2.031(B). Based on our understanding of the possible
federal charges and existing state charges, we do not think the petite policy would be an issue
should federal proceedings take place.
Federalism and Prosecutorial Discretion. All of the above issues essentially ask whether
a federal prosecution can proceed. We understand, however, that you also ask whether a federal
prosecution should proceed, even in the event that all of the elements of a federal offense could
be proven. On this issue, you raised two arguments: that the conduct at issue here is traditionally
a state concern because the activity is entirely local, and that the typical prosecution under federal
child exploitation statutes have different facts than the ones implicated here. You have
essentially asked us to look into whether a prosecution would so violate federal prosecutorial
policy that a United States Attorney's Office should not pursue a prosecution. We do not think
that is the case here for the following reasons.
Simply, the commercial sexual exploitation of children is a federal concern, even when
the conduct is local, and regardless of whether the defendant provided the child (the "pimp") or
paid for the child (the `John"). In your materials, you refer to a letter sent by the Department of
Justice to Congress in which the Department expresses concern over the expansion of federal
laws to reach almost all instances of prostitution. In that portion of the letter, the Department
was expressly referring to a proposed federal law that reach adult prostitution where no force,
fraud, or coercion was used. Indeed, the point being made in that letter is that the Department's
efforts are properly focused on the commercial sexual exploitation of children and the
exploitation of adults through the use of force, fraud, or coercion. As such, there is no
inconsistency between the position taken in that letter and the federal prosecution of wholly local
instances of the commercial sexual exploitation of children.
If Congress wanted to limit the reach of federal statutes only to those who profit from the
commercial sexual exploitation of children, or only to those who actually traffic children across
state lines, it could have done so. It did not. Finally, that a prosecution of Mr. Epstein might not
look precisely like the cases that came before it is not dispositive. We can say with confidence
that this case is consistent in principle with other federal prosecutions nationwide. As such, Mr.
Acosta can soundly exercise his authority to decide to pursue a prosecution even though it might
involve a novel application of a federal statute.
Conc/usion. After carefully considering all the factual and legal issues raised, as well as
the arguments concerning the general propriety ()fa federal case against Mr. Epstein on these
4
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05/16/2008 11:17 FAX
05/16/08 FRI 1110 FAX
Q5006/006
12006
facts, we conclude that federal prosecution in this case would not be improper or inappropriate.
While you raise many compelling arguments, we do not see anything that says to us categorically
that a federal case should not be brought. Mr. Acosta would not be abusing his prosecutorial
discretion should he authorize federal prosecution of Mr.. glutei
Sincerely
3. Oosterbaan
cc: .AAG Alice S. Fisher
DAAG Sigal P. Mandelkcr
U.S. Attorney R. Alexander Acosta
9:1
5
HOUSE OVERSIGHT 012674
TAB 39
HOUSE OVERSIGHT 012675
Jay Lefkowitz/New
York/Kirkland-Ellis
Sent by: Kristin Andersen/New
York/Kirkland-Ellis
12/12/2007 04:19 PM
To Ami Sheth/New York/Kirkland-Ellis@K&E
CC Eugene Kornel/New York/Kirkland-Ellis@K&E
bcc
Subject Fw: Epstein
---- Forwarded by Kristin Andersen/New York/Kirkland-Ellis on 12/12/2007 04:19 PM
Jay Lefkowitz/New
York/Kirkland-Ellis To "Sloman, Jeff (USAFLS)"
11/28/2007 04:29 PM cc "Acosta, Alex (USAFLS)"
Subject Re: EpsteinCi
Dear Jeff:
I received your email yesterday and was a little surprised at the tone of your letter, given
the fact that we spoke last week and had what I thought was a productive meeting. I was
especially surprised given that your letter arrived on only the second day back to work after the
Thanksgiving Holiday, and yet your demands regarding timing suggest that I have been sitting on
my hands for days.
You should know that the first time I learned about Judge Davis's selection of Podhurst
and Josephsberg, and indeed the first time I ever heard their names, was in our meeting with you
on Wednesday of last week. Nevertheless, I have now been able to confer with my client, and we
have determined that the selection of Podhurst and Josephsberg are acceptable to us, reserving, of
course, our previously stated objections to the manner in which you have interpreted the section
2255 portions of the Agreement.
We do, however, strongly and emphatically object to your sending a letter to the alleged
victims. Without a fair opportunity to review and the ability to make objections to this letter, it is
completely unacceptable that you would send it without our consideration. Additionally, given
that the US Attorney's office has made clear it cannot vouch for the claims of the victims, it
would be incendiary and inappropriate for your Office to send such a letter. Indeed, because it is
a certainty that any such letter would immediately be leaked to the press, your actions will only
have the effect of injuring Mr. Epstein and promoting spurious civil litigation directed at him.
We believe it is entirely unprecedented, and in any event, inappropriate for the Government to be
the instigator of such lawsuits.
Finally, we disagree with your view that you are required to notify the alleged victims
pursuant to the Justice for All Act of 2004. First, 18 USC section 2255, the relevant statute
under the Non-Prosecution Agreement for the settlement of civil remedies, does not have any
connection to the Justice for All Act. Section 2255 was enacted as part of a different statute.
Second, the Justice for All Act refers to restitution, and section 2255 is not a restitution statute.
It is a civil remedy. As you know, we had offered to provide a restitution fund for the alleged
HOUSE OVERSIGHT 012676
Jay,
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victims in this matter; however that option was rejected by your Office. Had that option been
chosen, we would not object to your notifying the alleged victims at this point. At this juncture,
however, we do not accept your contention that there is a requirement that the government notify
the alleged victims of a potential civil remedy in this case.
Accordingly, for all the reasons we have stated above, we respectfully -- and firmly --
object to your sending any letter whatsoever to the alleged victims in this matter. Furthermore, if
a letter is to be sent to these individuals, we believe we should have a right to review and make
objections to that submission prior to it being sent to any alleged victims. We also request that if
your Office believes that it must send a letter to go to the alleged victims, who still have not been
identified to us, it should happen only after Mr. Epstein has entered his plea. This letter should
then come from the attorney representative, and not from the Government, to avoid any bias.
As you know, Judge Starr has requested a meeting with Assistant Attorney General Fisher
to address what we believe is the unprecedented nature of the section 2255 component of the
Agreement. We are hopeful that this meeting will take place as early as next week. Accordingly,
we respectfully request that we postpone our discussion of sending a letter to the alleged victims
until after that meeting. We strongly believe that rushing to send any letter out this week is not
the wisest manner in which to proceed. Given that Mr. Epstein will not even enter his plea for
another few weeks, time is clearly not of the essence regarding any notification to the identified
individuals.
Thanks very much,
Jay
"Sloman, Jeff (USAFLS)"
1"Sloman, Jeff (USAFLS)"
11/27/2007 01:55 PM
To "Jay Lefkowitz"
CC "Acosta, Alex (USAFLS)"
Subject Epstein
Please accept my apologies for not getting back to you sooner but I was a little under the weather
yesterday. I hope that you enjoyed your Thanksgiving.
Regarding the issue of due diligence concerning Judge Davis' selection, I'd like to make a few
observations. First, Guy Lewis has known for some time that Judge Davis was making
reasonable efforts to secure Aaron Podhurst and Bob Josephsberg for this assignment. In fact,
when I told you of Judge Davis's selection during our meeting last Wednesday, November 2e,
HOUSE OVERSIGHT 012677
you and Professor Dershowitz seemed very comfortable, and certainly not surprised, with the
selection. Podhurst and Josephsberg are no strangers to nearly the entire Epstein defense team
including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Professor Dershowitz who
said he knew Mr. Josephsberg from law school. Second, Podhurst and Josephsberg have
long-standing stellar reputations for their legal acumen and ethics. It's hard for me to imagine
how much more vetting needs to be done.
The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of
the anticipated upcoming events and their rights associated with the agreement entered into by
the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since
you were formally notified of the selection. I must insist that the vetting process come to an end.
Therefore, unless you provide me with a good faith objection to Judge Davis's selection by COB
tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give
me the go-ahead on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously
send you a draft of the letter. I intend to notify the victims by letter after COB Thursday,
November 29th. Thanks,
Jeff
HOUSE OVERSIGHT 012678
TAB 40
HOUSE OVERSIGHT 012679
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-----Message from "A. on Fri, -----
To: "Lilly
Subject: Menchel
Dear Lilly:
Thank you for your letter of August 2nd regarding your proposal on how to resolve the Epstein
matter.
As we explained at our meeting on July 31, 2007, the Office believes that the federal interest
will not be vindicated in the absence of a two-year term of state imprisonment for Mr. Epstein.
That offer was not meant as a starting point for negotiations, it is the minimum term of
imprisonment that will obviate the need for federal prosecution. The Office has never agreed
that a state prison sentence is not appropriate for Mr. Epstein. Rather we simply stated that if Mr.
Epstein preferred to serve his sentence in a federal penetentiary, we would be willing to explore a
federal conviction that may allow that in lieu of any state resolution. Further, as I made clear in
HOUSE OVERSIGHT 012680
our follow up telephone conversation after the meeting, a plea to two federal misdemeanors was
never extended or meant as an offer.
We also would reiterate that the agreement to Section 2255 liability applies to all of the minor
girls identified during the federal investigation, not just the 12 that form the basis of an initial
planned charging instrument.
As you know, the ability to engage in flexible plea negotiations is dramatically changed upon the
return of an indictment. Once an indictment is returned, the Office does not intend to file a
Superseding Information containing a lesser charge or to dismiss the case in favor of state
prosecution.
Please let us know your client's decision by no later than August 17. I have conferred with U.S.
Attorney Acosta who has asked me to communicate that the two-year term of incarceration is a
non-negotiable minimum to vindicate a federal interest, and, at this time, he is not inclined to
meet with counsel for Mr. Epstein.
Sincerely,
R. Alexander Acosta
United States Attorney
By:
Matthew Menchel
Chief, Criminal Division
cc: Roy Black
Gerald Lefcourt
R. Alexander Acosta
Jeffrey Sloman
Andrew Lourie
A. Marie Villafaila
Margot Moss, Esq.
Fowler White Burnett, PA
Espirito Santo Plaza
1395 Brickell Avenue, 14th Floor
Miami, FL 33131
HOUSE OVERSIGHT 012681
TAB 41
HOUSE OVERSIGHT 012682
Jay,
10/31/2007 04:33 PM
To "Jay Lefkowitz"
cc
bcc
Subject Epstein
Your understanding from Jack Goldberger conforms to my understanding that Mr. Epstein's plea
and sentence will take place on the same day. I understand that the plea and sentence will occur
on or before the January 4th date.
Jeff
HOUSE OVERSIGHT 012683