EFTA00792400.pdf
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New York County Clerk's Index No. 30129/2010
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APPELLATE DIVISION-FIRST DEPARTMENT
PEOPLE OF THE STATE OF NEW YORK,
Respondent,
—against—
JEFFREY E. EPSTEIN,
Defendant-Appellant.
APPENDIX
CYRUS R. VANCE, JR. JAY P. LEFKOWITZ
NEW YORK COUNTY DISTRICT SANDRA LYNN MUSUMECI
ATTORNEY'S OFFICE 1Cnua-AND & Mem LLP
One Hogan Place 601 Lexington Avenue
New York, New York 10013 New York, New York 10022
Attorneys for Respondent
Attorneysfor Defendant-Appellant
REPRODUCED ON RECYCLED PAPER
EFTA00792400
TABLE OF CONTENTS
PAGE
Appellant's Pre-Argument Statement, dated February 9, 2011 Al
Appellant's Notice of Appeal, dated February 9, 2011 A3
Order Appealed From, dated January 18, 2011 with Notice of Entry A4
Palm Beach Police Department - Probable Cause Affidavit of
Det. Joe Recarey - Defendant dated May 1, 2006 A6
Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein,
dated July 23, 2006 A28
2006 Grand Jury Indictment of Felony Solicitation of Prostitution -
Jeffrey E. Epstein A29
Information for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 26, 2008 A31
Guilty Plea for Felony Solicitation of Prostitution and Procuring
Person under 18 for Prostitution - Jeffrey E. Epstein,
dated June 30, 2008 A32
Judgment for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 30, 2008 A33
Sentence for Procuring Person under 18 for Prostitution -
Jeffrey E. Epstein, dated June 30, 2008 A34
Community Control Standard Conditions, dated June 30, 2008 A35
Palm Beach Sheriffs Office Booking Card for Jeffrey Epstein,
dated June 30, 2008 A47
EFTA00792401
11
PAGE
Order Granting Jeffrey E. Epstein's Motion for Travel,
dated December 18, 2009 A48
Letter from Florida Department of Corrections Regarding Termination
of Supervision, dated July 21, 2010 A49
Letter from Palm Beach Sheriff's Office Regarding
Jeffrey Epstein's Participation in the Work Release Program,
dated August 12, 2010 A50
Letter from Jack A. Goldberger to NYS Sex Offender Registry
Regarding Florida Registration Level applicable to
Jeffrey E. Epstein, dated August 12, 2010 A51
Letter from Martin G. Weinberg to NYS Board of Examiners of
Sex Offenders Regarding Level and Designation Determination
for Jeffrey Epstein, dated August 16, 2010 A53
Letter from Stephen R. Alexander, Psy.D. to Jack Goldberger
Regarding Opinion of Jeffrey E. Epstein, dated August 16, 2010 A58
Recommendation of Board of Examiners of Sex Offenders, Including
Risk Assessment Instrument, dated August 19, 2010 and Case
Summary, dated August 23, 2010 A62
Letter from Supreme Court attaching Notification, Recommendation
and Notice of Right to Appeal, dated August 26, 2010 A67
Letter from Supreme Court to Jeffrey E. Epstein informing of SORA
Level Determination Hearing, dated August 26, 2010 A68
Order Sheet for Jeffrey Epstein, dated August 26, 2010 A69
Letter from Supreme Court to Counsel Informing of
SORA Level Determination Hearing (with attachment),
dated August 26, 2010 A71
EFTA00792402
iii
PAGE
Letter from Jay P. Lefkowitz to Hon. Ruth Pickholz Requesting a
Continuance of the Hearing, dated September 9, 2010 A77
Letter from Supreme Court to Sex Offender Registry Unit Enclosing
Final Determinations, dated January 19, 2011 A78
Court Action Sheet - Jeffrey Epstein, No. 30129-2010 A80
Handwritten Notations on Court Jacket - Jeffrey Epstein,
No. 30129-2010 A81
Transcript of SORA Hearing, dated January 18, 2011 A82
EFTA00792403
Al
Appellant's Pre-Argument Statement, dated February 9, 2011
(pp. Al-A21
SUPREME COURT FOR THE STATE OF NEW YORK
COUNTY OF NEW YORK
PEOPLE OF THE STATE OF NEW YORK,
Index No.: 30129-2010
Plaintiff-Respondent,
- against - PRE-ARGUMENT STATEMENT
JEFFREY E. EPSTEIN,
Defendant-Appellant.
1. TITLE OF ACTION: As set forth in caption.
2. FULL NAMES OF ORIGINAL PARTIES AND ANY CHANGE IN THE PARTIES:
As set forth in caption. There has been no change in the parties.
3. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR APPELLANT
OR PETITIONER:
Jay P. Lefkowitz, P.C.
Sandra Lynn Musumeci
KIRKLAND & ELLIS LLP
601 Lexington Avenue
New York, New York 10022-4611
Telephone: (212) 446-4800
Facsimile: (212) 446-4900
4. NAME, ADDRESS, AND TELEPHONE NUMBER OF COUNSEL FOR
RESPONDENT:
Cyrus R. Vance, Jr.
NEW YORK DISTRICT ATTORNEY'S OFFICE
One Hogan Place
New York, NY 10013
Telephone: (212) 335-9000
5. COURT AND COUNTY, OR ADMINISTRATIVE BODY, FROM WHICH APPEAL
IS TAKEN: New York Supreme Court (Criminal Term), New York County.
6. THE NATURE AND OBJECT OF THE CAUSE OF ACTION OR SPECIAL
PROCEEDING: Sex Offender Registration Act (SORA) hearing, pursuant to Article 6-C of the
Correction Law.
7. RESULT REACHED IN THE COURT OF ADMINISTRATIVE BODY BELOW:
Supreme Court, New York County, adjudged appellant Jeffrey E. Epstein to be a Level 3 sexual
offender, without additional designation.
8. GROUNDS FOR SEEKING REVERSAL, ANNULMENT, OR MODIFICATION: The
Court's designation of appellant Jeffrey E. Epstein as a Level 3 sexual offender was an abuse of
EFTA00792404
A2
discretion and constituted reversible legal error based, in part, on the following: (1) the Court
improperly relied on untrustworthy double and triple hearsay contained in the recommendation
of the Board of Examiners of Sex Offenders, even though the District Attorney, as the party
appearing on behalf of the State, rejected much of the Board's recommendation as not
constituting clear and convincing evidence to support a Level 3 designation where such hearsay
allegations were rejected as a basis for state prosecution; (2) the Court failed to provide the
parties with an opportunity to present evidence on contested issues, as required by statute, and
instead relied wholesale upon the recommendation of the Board, over the objection of the
District Attorney, without any inquiry; (3) the Court did not apply the guidelines established by
the Board, as required by statute; and (4) the Court failed to set forth the fmdings of fact and
conclusions of law on which its determinations in support of a Level 3 designation were based,
as required by statute.
9. THERE IS NO RELATED ACTION OR PROCEEDING NOW PENDING IN ANY
COURT OF THIS OR ANY OTHER JURISDICTION.
10. THERE IS NO ADDITIONAL APPEAL PENDING IN THIS ACTION.
Dated: February 9, 2011 Ja . Lefkowitz, P.C.
S dra Lynn Musumeci
KIRKLAND & ELLIS LLP
601 Lexington Avenue
New York, New York 10022-4611
Telephone: (212) 446-4800
Facsimile: (212) 4464900
Attorneysfor Defendant-Appellant Jeffrey K
Esptein.
-2-
EFTA00792405
A3
Appellant's Notice of Appeal, dated February 9, 2011
SUPREME COURT FOR THE STATE OF NEW YORK
COUNTY OF NEW YORK
THE PEOPLE OF THE STATE OF NEW NOTICE OF APPEAL
YORK,
Index No. 30129-2010
Plaintiff,
CRIMINAL TERM PART 66
- against - JUSTICE RUTH PICKHOLZ
JEFFREY E. EPSTEIN,
Defendant.
PLEASE TAKE NOTICE that the above named defendant, Jeffrey E. Epstein, hereby
appeals to the Appellate Division of the New York Supreme Court in and for the First
Department, from an order entered in the above entitled action in the office of the Clerk of New
York County on the 18th day of January 2011, which order adjudged defendant Jeffrey E.
Epstein to be a Level 3 sexual offender pursuant to Article 6-C of the Correction Law, and this
appeal is taken from each and every part of that order as well as from the whole thereof.
Dated: February 9, 2011
Lefkowitz, P.C.
To: dra Lynn Musumeci
KIRKLAND & ELLIS LLP
Clerk, New York County 601 Lexington Avenue
New York, New York 10022-4611
Cyrus R. Vance, Jr. Telephone: (212) 446-4800
NEW YORK DISTRICT ATTORNEY'S Facsimile: (212) 446-4900
OFFICE 1.
One Hogan Place Attorneksfor Defendant
New York, NY 10013 Jeffrey E. E
Telephone: (212) 335-9000
PFetPth I LED
FEB 0 9 2011
IESUPRUME COURT
NEW YORK COUNTY
APPSALn C41.1911eO1/41.3
EFTA00792406
A4
Order Appealed From, dated January 18, 2011 with Notice of Entr)
[pp. A4-ASI
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EFTA00792407
A5
SUPREME COURT FOR THE STATE OF NEW YORK
COUNTY OF NEW YORK
THE PEOPLE OF THE STATE OF NEW NOTICE OF ENTRY
YORK,
Index No. 30129-2010
Plaintiff,
CRIMINAL TERM PART 66
- against - JUSTICE RUTH PICKHOLZ
JEFFREY E. EPSTEIN,
Defendant.
PLEASE TAKE NOTICE that the within is a copy of an order entered in this action on
the 18th day of January 2011, in the office of the Clerk of the County of New York.
Dated: February 9, 2011
Jafi . Lefkowitz, P.C.
To: Sandra Lynn Musumeci
IURKLAND & ELLIS LLP
Clerk, New York County 601 Lexington Avenue
New York, New York 10022-4611
Cyrus R. Vance, Jr. Telephone:
NEW YORK DISTRICT ATTORNEY'S Facsimile:
OFFICE
One Hogan Place Attorneysfor Defendant Jeffivy E. Epstein
New York, NY 10013
Telephone:
Fit . E D
FEB 0 P 2011
NNW - Iv! Couin.
AsPiAte
CInic COUtirry
OUR/Au
EFTA00792408
A6
Palm Beach Police Department - Probable Cause Affidavit of Det. Joe Recarey - Defendant
dated May 1, 2006
Ipp. A6-A27]
Probable Cause Affidavit
Palm Beach Police Department
Arley ORIN FLO 500600
Police Case#: 05-368 (2)
Defendant:
Race/Sex: White Female
DOB: 05-25-1975
Charges: Principal in the 1" Unlawful Sexual Activity with a Minor (4) counts
Principal is the 1" Lewd and Lascivious Molestation (1) count
From March 15, 2005, through February 2006 the alm Beach epartment conducted a sexual
battery investigation involving Jeffrey Epstein, and . Sworn taped statements were
taken from five victims and seventeen witnesses concerning massages and unlawful sexual activity that took place
at the residence of Jeffrey stet 358 El Brill° Way, Palm Beach. Several of the vic e recruited by and
brought to the residence by to perform massages for Epstein for w 'ch received
monetary compensation. During e visit they would be introduced to Epstein's assistant, who in
turn would record their telephone numbers and name. The victims would be brought to Epstein's bedroom to
provide the massage. Epstein would enter the room and order the victims to remove their clothing to provide the
massage. As the victims complied and provided the massages, Epstein would rub his fingers on their vaginas.
On occasion, Epstein would introduce a massager/vibrator and rub the victims vaginas as they provided the
massage. On three separate occasions, Epstein had intercourse and inserted his penis/fingers in the victims
vaginas. At the conclusion of the massages the victims were paid sums of money ranging from 8200 - $1,000.
The facts, as reported, are as follows:
On 03/15/2005, A fourteen year old white female, hereinafter referred to as "SG," dob la and
her family reported unlawful sexual activity which occurred at a residence within the Town of Palm Beach. SO
reported that a subject known to her as "Jeff' had touched her vaginal area with a vibmtothttassager while within
his residence. "Jeff' was later identified as Jeffrey Epstein through a photo line up.
During a sworn taped interview, SG stated that dob a cousin of SG's
boyfriend and classmate at worked for a wealthy man and did sexual favors for
him. She also admitted that had offered her an opportunity to makeinas During the beginning of
the month ofFebruary 005 SO explained that she was first approached by to go with her to Epstein's
house. SO stated that along with a Hispanic female, later identified at pick her up at
her father's house on a Sunday. SG was not sure of the exact dates but knew it was a Sunday. SG told her
father that they were going shopping but in reality drove them to Palm Beach. During the drive a
The foregoing instrument was sworn to or affirmed State of Florida
before me this 1" day of May, 2006 by County of Palm Beach
Det Joe Recarcy, who is personally known to me.
Signatu Officer
Signature of Police Officer (F.S.S. 117.10) Date: 05/ 006
Page I of 22
EFTA00792409
A7
Probable Cause Affidavit
Palm Beach Police Department
Agency ORIN FLO 500600
conversation occurred between and SG whereas reportedly tob t if Jeff asked her age,
she should say sbc was eighteen later co.0's.father that picked his daughter up
on February 6, 2005. According to SG's father, drovc a pick up truck.
• SO described Epstein's house as a two-story pink house with a Cadillac Escalade parked in the
driveway. Shc recalled that Jeff's house was on a dead end street. Upon arriving at the house SO stated that
they walked up a driveway ast what appeared to be a small guard/security room. A male approaching them
asking what they wanted. stated they were there to see Epstein. The male allowed them to continue
walking up to the house. S e the man told them that Epstein was not there but was expected back. He
allowed them to enter the house, via the kitchen. He offered them something to drink while they waited inside.
Short!ii thereafter, Epstein and his assistant, described as white female with blond hair andlater identified as
entered the kitchen. Epstein introduced himself to SG. SO described Epstein as being
approximately forty-five years old, having a long face and bushy eyebrows, with graying hair.
and Epstein left the kitchen leaving SG alone in the kitchen. They returned a short time later.
They allilbriefly in the kitchen. SG was instructed to follow upstairs. SG recalled walking up a
flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there
was a large bathroom to the right and a hot pink and green sofa in the room. There was a door on each side of
the sofa. SG recalled there., a mural of a naked woman in the room, as well as several photographs of
naked women on a shelf. told the victim that Epstein would be up in a second.
Epstein entered the room wearing only a towel and told SO to take off her clothes. SG stated Epstein
was stem when he told her to take off her clothes. SG said she did not know what to do as she was the only one
there in the room so she took off her shirt leaving her bra on. Epstein had removed his towel and told the SG to
take off everything. SG stated Epstein was nude when he took his towel off, placing it on the floor as he laid
down on the table. SG stated she then removed her pants leaving her thong panties on. Epstein then instructed
her to give him a massage pointing to a specific lotion for her to use. As SG began to give Epstein the massage,
he told her to get on his back. SG stated she straddled herself on Epstein's back whereby her exposed buttocks
were touching Epstein's bare buttocks. SG said Epstein was specific in his instruction to her on how to massage
him, telling her to go clockwise or counter clockwise. Epstein then turned over and instructed SO to massage his
chest SG was now standing on the ground and resumed massaging Epstein's chest area. SG stated Epstein held
onto the small of her back as she massaged his chest and shoulder area. Epstein then turned to his side and
started to rub his penis in an up and down motion. Epstein then pulled out a purple vibrator and began to
The foregoing Instrument was sworn to or affirmed State of Florida
before me this 1" day of May, 2006 by County of Palm B 'b
Det Joe Recarcy, who is personally known to me.
Signatur g Officer
Signature of Poli a Officer (F.S.S. 117.10) Date: 05 006
Page 2of 22
EFTA00792410
A8
Probable Cause Affidavit
Palm Beach Police Department
Agency ORM FLO 50600
massage SG's vaginal area. SO stated there was no penetration as the vibrator was on top of her underwear.
SG recalled Epstein ejaculating because he had to use the towel to wipe himself as he gwarjhe table. Epstein
then left the room and SG got dressed. She went back downstairs where she met with M. SG said she
was paid three hundred dollars in cash from Epstein. Before she left Epstein asked SO to leave her phone
number. As SG, and Figueroa were leaving the house, told SO she received two hundred
dollars that day fo bringing her.
During the course of the investigation, parental consent was granted for SG to assist with the
investigation. At our direction SG conducted controlled taped phone calls to cellular telep -
308-0282. SG spoke with in an attem,range another meeting with Epstein. SO asked
what did she need to do to made stated, "the more you do, the more you get pai ."
had subsequently called back SG and left a voice mail message for her indicating that she had set up an
appointment for SG to go to Epstein's house at 11:00 am on April 5, 2005. This message was recorded from
SG's voice mail.
Based on the above, trash pulls were established at Epstein's residence with Supervisor Tony Higgins of
the Sanitation Bureau of the Town of Palm Beach. The trash pull from April 5, 2005 revealed iiiiiihone
message for Epstein which stated Haley and SG's name at 11:00 ant This was the time frame had
informed SG to be ready to go work at Epstein's house.
On October 3, 2005, Sgt Prick and I went to residence and viewed her vehicle parked in the
driveway, a red Dodge Neon. Sgt Frick and I knocked on the door and met with was
told that we were investigatingn claim involving Jeffrey Epstein of El Milo Way, in Palm Beach. was
asked if she would accompany us back to the police station for further questioning. She was also told that at the
conclusion of the interview she would be returned home. voluntarily came with us back to the Palm
Beach Police Department.
Upon our arrival at the police station, was brought to the interview room in the Detective. ureau
where I obtained a taped, magtatement. I began the interview by asking how she became
acquainted with Epstein. M state approximately two years ago, just a er she turned 17 ears of age,
she was approached by a friend named at the Canopy Beach Resort in Rivera Beach, was asked
e wanted to make money. She was told she would have to provide a massage and sho m e $200.00.
Lik thought about the offer and agreed to meet with Jeffrey.
The foregoing instrument was sworn to or *funned State of Florida
before me this 1" day of May, 2006 by County of Palm Beach
Det Joe Reearcy, who is personally known to me.
Signature Officer
Signature of Police fficer S. 117.10) Date: 05/0 006
Page3of 22
EFTA00792411
A9
Probable Cause Affidavit
Palm Beach Police Department
Apo ty ORM FLO 500600
II (Unknown last name) and Tony (Unknown last name) picked= up and she was taken to
Epstein s ouse. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She
was also introduced to a white female known to her as She was led upstairs to the main bedroom known
to her as Jeff Epstein's bedroom. arranged the massage table vered the table with a sheet. She
brow t out the massage oils and tar t m next to the massage bed.t then left the room and informed
Jeff would be in, in a minute. Jeff entered the bedroom wearing only a towel. He removed the
en nude on the massage table. He laid on the table onto his stomach and picked a massage oil for
to nib on him. During the massage, stated "He tried to touch me and I stopped him." 1 ow he
tried to touch her. stated that Epstein grabbed her buttocks and she felt uncomfortable. told
Epstein, I'll massage you but I don't want to be touched. stated she performed the massage naked. At
the conclusion of the massage, Epstein paid $200.
After the massage Epstein stated to that he understood she was not comfortable, but he would
pay her if she brought over some girls. He told her the younger the better. stated she once tried to bring
a 23 year old female and Epstein stated that the female was too old. stated that in total she only
remeinbers six girls that she brought to see Epstein, each time she was paid S200. stated she had
brought the following girl : , J.S. ( al6 year old female), XL (a 16 year old
female) and T.._.• — , :. said that at the time she brought thesetisto Epstein's house they were a1114
through 16 years of age. I asked which one was the youngest. advised SO was the youngest as
she was fourteen when the massage occurred. stated every girl she brought knew what to expect when
they arrived. They were told they would provide a massage, possibly naked, and allow some touching. I asked
her if SO was aware. She stated every girl she brought knew what to expect. She explained she knew that SO
wanted to make money. She approached SG and explained about going to work for Jeff, SO agreed and
arrangements were made to bring her to Epstein's house on a weekend. stated that she and _
(Later identified as -......_ 7... ... ) picked up SO at her house. stated that at that time she was driving
a red pickup truck. They traveled tein's house and entered through the kitchen door. They met with the
chef and Epstein's assistant SO was introduced to Epstein while they were in the kitchen area.
li SG upstairs and Epstein went upstairs. When the massage was over SO returned to the kitchen area
r stated she was paid $200.00 for bringing SO to Epstein's . house.
paid $300.00 for the massage.
stated SO told her she was
stated that SG was t person she brought to Epstein's house. She had changed her cellular
number to avoid being contacted by . She continued stating that she had no direct contact with Epstein
The foregoing instrument was sworn to or affirmed State of Florida
before me this r day of May, 2006 by County of Palm Beach
Oct Joe Reearey, who is personally known to me.
Signatur 'g Officer
K
Signature of Police ffice (F.S.S. 117.10) Date: 05/01/2006
Page lief 22
EFTA00792412
A10
Probable Cause 4,ffidavit
Palm Beach Police Department
Agency ORD FLO 500600
when he was going to travel to Pal Beach. sai Epstein announces to his assistant,
he is traveling to Palm Beach, would then contact to arrange girls to "wotk" for Epstein.
stated that once herparents discovered that visiting Epste•
and she stopped. further stated that
nigi
still tries to call
approved of the encounters with him
house and leaves messages.
Sgt Frick entered the room and explained to that her own statements, she had
implicated herself by bringing underage girls to Epstein's house. provided cellular telephone numbers for
the girls she had mentioned previously. Additionally, she also provt . possible addresses and areas in which
they lived.
Asp was being taken home in the vehicle, a tape recorder within the vehicle to record
any cone ons within the vehicle. During the drive back to her home, ade the co
mm " I'm like
a Heidi Fleiss." (Hollywood Madam who sent girls to clients for sexual favors in California). VMS
dropped off at her house without incident.
On October 3, 2005, Sgt Frick and I went to speak with JS, a sixteen year-old female who was
brought to Epstein's residence by MB We met with JS's mother at their font door. We explained
the ongoing investigation and asked to speak with JS as we had information that she had "worked" for Jeff.
Mrs. S introduced us to her husband and allowed us entry into the home. We sat in the dining room and met
with JS, Date of Birth MI As she was under the age of eighteen, Mrs S was advised we would be
speaking with her. She expressed if her daughter had information, she wanted to assist, We interviewed JS, who
denied havin any inappropriate encounters with Jeff (Epstein). She stated she had gone to Jeff's house with
approximately eight months ago and sat in the kitchen with the house chef, but nothing happened.
As the parents were present during the interview, we felt that JS was withholding information from us. She made
several comments as to putting the entire incident behind her. I my telephone number and advised should she
wish to speak with me again to telephone me. Sgt Frick and I thanked Mrs. S for her time and left the area. She
stated she would ask JS again after we left as to what happened at Epstein's house. I informed her that IS had
my telephone number and hopefully she would call.
On OctoberS2005, Dot Dawson and I drove to the ' •• home and met with L.._...i_ 7 .... * and
,. , dob During a sworn taped statcmcn . ._ . . • stated approximately a year ago.
because they both attend mairm
when she was seventeen years old, she was taken to a house b . stated she knows
. She was told she could make money working
The tangoing instrument was sworn to or affirmed State of Florida
before me this I" day of May, 2006 by County of Palm Beach
Act Joe Recarey, who is personally known to me.
Signatur 7j, es ng Officer
Signature of Police facer .S.S. 117.10) Date: 05/01/2006
PageSof 22
EFTA00792413
All
Probable Cause Affidavit
Palm Beach Police Department
Agency ORIN PLO SON‘00
for Jeff. She was told she would have to provide a massage to Jeff. stated upon her arrival to the house
. she was brought to the kitchen area by They met with the house chef who was already.,
area. . stated would wait for her in the
assistant, who brought her upstairs to the master bedroom.
I , was introduced to Jeff's
repared the room and massage table for a
massage. Epstein entered the room wearing only a rowel and she provided a massage. 7 • 't stated she kept
her clothes on during the massage. She advised sometime during the massage, Epstein grabbed her buttocks and
pulled her close to him. I said she was uncomfortable by the Incident involving Jcff At the conclusion of
the massage, she was paid 8200.00 for the massage. I asked : ..._•_. if she has any formal training in massages to
which sil ied no. I asked her if =received any monies for taking her to perform the massage.
stated ad received money for taking her there but was unsure in the amount 1 lc stated she
returned to Epstein's house on another occasion with and another' ic stated
she waited in the kitchen with is while :L._ was taken upstairs by stated she only did the
massage once as she was uncomfortable with the whole experience.
At the conclusion of the interview, the tape was stopped. I was informed that Illhad attempted to
read via cell phogLa voice mail message on October 4, 2005 at 10:59 run, revealed a female voice
who identified herself as who request : to her back reference the police questioning.:..,
provided the incoming telephone number . stated she inadvertently told .
about the police investigation because ::_ had called her to tell her about how she just received a rental car
from left Epstein. had called her to tell her that she was given a rental car, a 2005 Silver Nissan Sentra,
to utilize to visit family and visit Epstein. : „..." asked her what was on at the house that the police would
be asking questions. .- . • stated thenealted Jeff and and asked what was going on
reference the ongoing police investigation. According to - since then been trying to contact her
to ask about the police questions. I instructed 7 ' ' not tow tact and do not provide any more
information to .-__ as she would notify Jeff Epstein and MIE what was transpiring.
On Ootober4, 2005, I made telephone contact with JS who had left several messages for me to contact
her. During the message, she advised she was not completely truthful when we met in person but would like to
speak with me to advise what had happened. She further advised she did not want to speak of this incident in
front of her mother. At approximately 3:48 pm I made telephone contact with .15. During a taped recorded
statement JS stated the following: approximately a year ago, when she was sixteen years took her
to Epstein's house twice. She knows because they both attend Royal Pal Beach The first
time she went, drove to the house. They entered through the kitchen area where she was
The foregoing instrument was sworn to or affirmed State of Florida
before me this fa day of May, 2006 by Coun of Palm Beach
bet Joe Recarey, who is personally known to me.
Signatur A ti g Officer
711t
Signature of Police Meer .S.S. 117.10) Date: 05/01/2006
Pagel/of22
EFTA00792414
A 12
Probable Cause Affidavit
Palm Beach Police Department
Agency ORM FLO 500600
introduced toand Epstein. She was taken upstairs to a bedroom by who set the room up with a
massage bed and brought out the oils to use. Epstein then entered the room wearing a towel. He laid on the
table and picked out a lotion for JS to rub on hint. At one point during the massage he tried to remove her shirt,
at which point she became very upset and discontinued the massage. • stein had a verbal
disagreement, at which time she left without being paid. She got with who was sitti '
kitchen and told her "let's go." JS advised she received no money for that day. JS also said that
had told her if she was uncomfortable with what was going on, to let him know and he'll stop. She knew that the
more you do the more you get paid. IS advised that several weeks later she agreed to be taken second time
by . Once they arrived at the residence, Haley•Robson sat in the kitchen and took her
upstairs to the master bedroom again. set the room up with a massage bed and brought out the oils to
use. Epstein then entered the room wearing a towel. He laid on the table and picked out a lotion for JS to rub
on him. At one point during the massage he tried to touch her buttocks. As IS was wearing tight Jeans and had a
tight belt on Epstein was unable to touch her buttocks. Epstein then rolled onto his back during the massage and
then attempted to touch her breasts. /5 then became upset again and told Epstein she didn't want to be touched.
JS discontinued t e assage and was paid $200.00. JS then went downstairs where was waiting
for her. She told she wanted to leave. IS said she never returned to the house. JS stated she is aware
that her friend, ____ : was also at the house and had a problem with Epstein.
\1
I later researched :, dot and met with her at her residence. Durin a sworn
las t e ent - stated the following: tn dorttabout ember 2_00,,.shewas approached at money.
by fellow so asked .t. she wanted to make
She agreed and was told she would provide a massage to wealthy man in Palm Beach. picked her up
and drove her t a house in Palm Beach. She was brought into the kitchen area of the house. he further stated
that fellow students YL and • .) came with them. They were
brought into the kitchen where she was introduced to Epstein and other females. _ stated she was
introduced to a female helper of Epstein, the female was described as white female (unknown name ), with
blond hair. She stated that the assistant was familiar with . The assistant brought her upstairs into a
master bedroom area. The assistant set up the massage tab e an put out lotions to be used. She told - •
Epstein would be available in a minute. Epstein entered the room wearing only a towel. Epstein removed his
towel, and laid naked on the massage table and picked a lotion to rub on his thighs and back. . ' ' ' further
stated during the massage, Epstein asked her to remove her clothes. She complied and removed her pants and
blouse. didn't remember if she had removed her bra but feels that she did. - . ' ' was certain that she
stayed in her thong underwear. • • continued the massage and at one point sbe climbed onto the massage
The foregoing instrument was sworn to or affirmed State of Florida
before me this 1" day of May, 2006 by County of Palm Be h
Pet Joe Recarey, who is personally known to me.
Signatur g Officer
Signature of Police Office (F.S.S. 117.10) Date: 0510 /2006
Pagel of 22
EFTA00792415
A13
Probable Cause Affidavit
Palm Beach Police Department.
Agency ORIN FLO 50n600
table, straddling Epstein to massage his back. While doing this her buttocks were touching Epsteins.
was instructed to return to the ground at which time Epstein turned to have his chest rubbed. ' advised she
was sure he was masturbating based on his hand movements going up and down on his penis area. 7.. .. ' did
not want to look at his penis area because she was uncomfortable. Epstein removed a large white vibrator which
was next to the massage table and turned it on. 1..2.: . stated Epstein began rubbing the vibrator over her thong
underwear on her vaginal area. Shortly thereafter, Epstein ejaculated and removed himself from the table. Be
walked over to where the shower was and opened the glass door. She waited as he was taking a shower in her
direct view. When I asked how old she was when this occurred, she stated she had just turned
seventeen.. At the. conclusion of the shower, I. was paid either $350.00 or $400.00. She stated she
wasn't sure, but knows it was close to $400.00. stated she never returned to provide a massage for
Epstein.
At approximately 2:10 pm, Det Dawson and I met with YL, doba. at her residence. As YL,
was only seventeen years of age, I had notified her mother, that she would be interviewed reference an ongoing
investigation in Palm Beach. h assured her that her daughter was not a suspect. I explained the possibility of her
being either a witness or victim. Mrs L advised she wanted YL to cooperate and consented to the interview.
During a sworn taped statement, ollowing: at the age of sixteen, during the month of
September 2004 she was approached by for a chance to make money. YL was fri
associates o and knew the same people. een previously told by her frien
, what did for Epstein. called a person known to YL as and
scheduled the appointment. picked YL up and drove her to Palm Beach to a street called "BriIto Way".
They drove to the end of the street and entered a large die They entered the kitchen arca of the house and
met with Epstein. YE, was introduced to Jeff Epstein. led YI. upstairs to the main bedroom ar
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Document Metadata
- Document ID
- 02cd4db2-5936-476d-b188-2eb8761f5806
- Storage Key
- dataset_9/EFTA00792400.pdf
- Content Hash
- c1479f32021a09adc9d06753b2c43f50
- Created
- Feb 3, 2026