EFTA01308891

Case Report OCVAN S4SS CortOW 561a65474 9. 51-0,..5.9453 2002-10 Palm Beach Police PcionOixch FL nevolaw rows UnveDvIc reanflm late IS. I ralkfu 12/0611901 / / // Prenwy I Prostitution-Epstein M A. MOO Amu{ I Active UNFOUNDED l Asenq Lois /sees/ Cue Ueda) I mg I G4 r r Re Make earflemd liecordly aflateUrdatW 300-13 08/06/2004 l imper( 0 81062004 Import I Narrative/Notes 12/07/01 File 100 Sgt. On 12/06/01, OCVAN received intelligence from the WPBPD concerning Maxwell. According to the report, Maxwell is hiring young women from PBAC to come toher house and answer the phone. They are paid $200.00 per day for htis service. It is unclear what is occurring in the residence, however, contact information for PBAC students was provided. Follow-up will be initiated as soon as possible. File 300-13 Det. On 12/10/01, information was passed on from Sgt. regarding Ghislaine Maxwell and Jeffrey Epstein of 358 El Brillo way. A west Palm Beach intern. once report read as follows: "Three female college students from PBAC and 2 were approached by an Eng is woman w o isenti ie• erse as Maxwe , on the Palm Beach Atlantic Campus. Maxwell said she needed young, beautifu l unmalried women to answer phones and do office work at her home on Palm Beach. went to the house on several occasssions and described the telephone ails as mon call in saying when they were going to drop of particular girls. All three girls said Maxwell and Epstein were secretive about what was going on at the house, and at least two of the girls complained about Epstein touching them inappropriately. They said Maxwell asked for a list of other girls who she could call to work on short notice. She said she needed a large pool of girls to call as she did not know how many she would need at any given time. The callers were receptive to the idea of forwarding numbers of undercover personnel to Maxwell. Maxwell pays $200.00 per day for answering phones (cash). said she only worked there one day, but she hd been there on at least one other occasion. I did not speak with . Their telephone number is at their dorm room on campus (roommates). Maxwell and Epstein allegedly have a private plane and frequently go to Now York leaving them out of the area for extended periods of time." Numerous attempts were made to roach the girls at the above listed number with negative results. Finally, I contacted PBA security who stated the college was closed for the semester and would not re open until next year. In the beginning of January, many messages were left which met with negative results. Page 1 o14 memo thug Teal Ithiewa Mareavamea. conett• knew. of letior I “IneIvr• sad Nlameamaar . !Mynah. /Ind. CONFIDENTIAL SDNY_GkL00329836 EFTA_00202562 EFTA01308891 Narrative/Notes A check of Jeffrey E Epstein, DOB 01/20/53, revealed an license of E-123-425-53-020 expired florida drivers -0. Epstein did not return An Accurint check revealed with any criminal history. he has a florida conceale which expires on 03/29/05. d weapon permit 19012027, Several ownership address including 358 E/ Brillo Way, were listed for Epstein Palm Beach, 457 Madision numerous vehicle and wate Ave, New York, NY, and rcraft ownerships. In addi recorded. Finally, associat tion, many UCC filings were ions were listed with the foll Ghislaine Corp (Inactive); owing companies: Har Adom, Limited (CO-Active); Management (GA-Active); Nine L.A.W. Plantation East 71st street Corp. (NY- Corp (TX-Dead); and the othe Active); RHC Licensing r two Florida inactive corp orations. A check of Ghislaine Noelle Maxwell, DOB 12/25/61, reve license SW 240-294-91-965-0 aled a valid florida driver , with no criminal history. Maxwell revealed numerous An Accurint check on vehicles, with nothing addi tional. On 1/28/02, trash pulls were initiated on this caso, and through 4/16/02. Numerous conducted intermittently intelligence items were disc include: individual dire overed within the trash, to ctory listings for massages Kingdom, numerous phone mess in New York, and the Unit ages, daily calendars, list ed "People that I want you to of female names titled meet", listing females, ages they do (trash pull on 3/29 , descriptions, and what /02), front page of bell sout phone account h phone bill indicating under the name of Jeffrey Epst under the name of Ghislainne ein and account in cate a weapon s kept Maxwell, correspondence to on the property, financial of women and numerous refe information, nude photographs rences to massages through messages, etc. It should be daily calendars, phone noted a list was complied of with Epstein/Maxwell/358 El all names associated Brillo Way, and is document ed in the file. It should be noted that all attempts to reach reporting negative results at this time parties have met with . On 02/8/02, an investigativ e subpoena was completed requ outgoing lines to the address esting all incoming and 358 El Brillo Way. On 02/13/02, the above refe renced subpoena was received served on Bell South via fax. from the SAO and was On 02/12/02, an inquiry into corporations on line revealed related to three Florida enti Jeffrey E. Epstein ties: Financial Strategy Grou Financial Trustees, Inc. None p, Inc; Ghislaine Corp; of the aforementioned entities are active. On 02/22/02, I received informat ion from Bell South which reve telephone lines are installe aled the following d at 358 El Brillo Way: Under name G. Maxwell Jeffrey Epstein Main house line All above lines are consider ed to be residential linos. On 02/27/02, an investigative subpoena was completed requesti outgoing calls rom 1/28/02 thro ng all incoming and ugh 2/4/02 on the following telephone numbers: IIII Elft2L1DSilattiathEatela Page 2 of 4 MisTrikedipegUswwimntin.ftm otdftlaTM..4,5.4M! , bctlomat. Ihmda CONFIDENTIAL SONY_GM_0029837 EFTA_00202563 EFTA01308892 Narratiffre/Notes On 0///i/U2, 411 computer checks revealed the lines and to be listed under the name Jeffrey Epstein. On 03/1/02, the above referenced subpoena was received from the SAO and was served via fax to Bell South. On 03/5/02, a fax was received from Bell South indicating the subpoena has been received and Bell South was working on the informatio n. On 03/11/02, documents phone records were received from Bell South and evaluated. With the exception of their being numerous phone lines at the residence, nothing unusual was detected. On 03/19/02, an investigative subpoena was completed requesting all incoming and outgoing calls rom 1/28/02 through 2/4/02 on the following telephone numbers: IIII and On 03/20/02, the above referenced subpoena was received from the SAO and was served via fax to Bell South on 03/21/02. On 03/26/02, drive by surveillance revealed the following vehicle tags: F58XCK; Jeffrey Epstein, F57XCK; Jeffrey Epstein, and F47WCV; On 03/29/02, additional phone records from Bell South were received and evaluated. It should be noted nothing usual was detected within these records. I subsequently contacted security at PBAC and advised them of the information received from WPBPD. They provided the following informatio n: I and are now living off campu term •hysical address is p ysical address is Security stated these two girls ma and their phone number is . In addition, lis residing on campus at a different location than last semester. Security agreed to conduct an unannounced room search on and advised will me as soon as that is complete. I advised them I will not attempt contact until the search has been done. On 04/12/02, 1 was contacted by PBA Security. A room search was conducted and the fo lowi g report provided: "At 1420, 020411 a room search was conducted in by Sgt. , Officer and the Director of Security Allen MCEniry, per the request of Residential Life (Eric Lowdermilk ). Kim Ladd accompanied the officer's to was not present during the search. Six full bottles and two empty bottles of Smirnoff Ice were found in ing closet. Along with the illegal alcohol, several papers were found by personal laptop computer that had what appeared to be porn site address s on them. These papers were not confiscated due to there being other personal related information on them. A check of the one address: www.enjoy.com proved to be an adult internet sit with visual pornography on it. Another piece of paper that was seen indicated that informatio n had been obtained about some type of adult work that paid $2,200.00 weekly. Nothing else found. Eric Lowdermilk is handling all discipline." 7002.10 -Pmmittedon-Fowgth Page 3 of 4 DOW Tin kanita". MannaII %rAna • Winne era. Teontrf•M Iboite I twoafr. OWd. CONFIDENTIAL SDNY_GPVL00329838 EFTA_00202564 EFTA01308893 Narrative/Notes explained to me that will no longer be allowed PBAC campus, however, he to reside at the will n act me with whatever addr ess she moves to. Later, I was h the following address for . A cell phone number o was provided for On 04/24/02, Sgt. and I interviewed confirmed they had been I approached by Maxwell and and I N Both subjects briefly answering phones, had worked at the residenc and were paid well. e something "weird" about the felt there was subjects residing there, did not observe anything and advised they illegal at the time. On 04/25/02, Sgt. and I met with not recall anything illegal . stated that she did occurring a real ence, photographs of women all over tare wore nude the residence. 1 added there were women runnin around the pool area topl ess, and that people were stated that Epstein offe always getting massages. red a massage to at one time, (he did not do the massage-a tech did physically it), but Epstein il a l her take her top off massage. I istated that made her extr for the back since. emel y uncomfortable and she has not been Although it appears as thou gh usual activity is occu this time, no illegal acti rring at this residence, vity has been reported at will remain as intellig or detected. This information ence purposes only, unti another student or young l a crime is reported or poss female and report to us whil ibly e working at the residenc e. Links Expenses/Income 0 Source Payments Aircraft 0 0 Associated Cases 0 Arrests 0 Arrest Charges 0 Arrest Warrants 0 Businesses Case Logs 0 0 Confiscations and Seizures 0 Associated Employees Evidence 0 Gangs and Groups 0 Locations 0 Media 0 People 0 Search Warrants 0 Vehicles 0 Watercraft 0 va2-10 -PrOstitMon.f0M60 Pmc J 44 nq Ti Istagento Madwatta "Mao • Inuitio of Pay, rocintlein ad Minorc an! . CONFIDENTIAL SDNY_GM_00329839 EFTA_00202565 EFTA01308894 Persons System Report ADULT °CYAN UM (414304474 Palm Beach Police 315$ Cant,RO 56I 455-96.53 two Palo Beath a Adkna 1011812005 Epstein.JeffieyE I/ON 358 El 8rillo Way Palm Beach. FL 33480 . woo I -1Y1 I'm "ant 01/20/196.1 Aniilitino AP'521 is"M1 Mitr#172 4" CAUCASIAN WW 0 -- --- mwaa-ir --- Away Nutho I Otho hbabto r; earn Sto/Alvlo ow. 300-1312600- No Photo Available /1 INTEL REPO Ara Mor/7— Addresses 358 EL BRILLO WAY PALM BEACH, FL 33480 Import From Per: Associates Urtkno... Girlizi Maxwell, Ghislaine W/F X1 1 Media EPSTEIN17S IMAGE EPSTEIN_175.JPG Notes See Drug Trak Case #2002-10 See associate Ghislaine Maxwell 03-11-04 File I 2600 Det. Silvestri On 03-05-04, Sgt. completed an intel regarding a unknown, who was giving a message to last name Jeffery Epstein at grille. stated that several times Epstien asked her to take off her top or her pants refused. I [contacted the police department later . She a complaint. She also said that she that day and wanted to make would work with police. I contacte on 03-06-04 at 11:00 p.m. and introduced da myself then told her that I wouild her at a later date. contact On 03-11-04, I left a message for to call me regarding the Epstion incident. Her phone number is Investigation Continues File 2600 August 10, 2004 Dot. CONFIDENTIAL SONY_GM_00329840 EFTA_00202566 EFTA01308895 Notes On August 10, 2004 I received an intelligence report written by Off. indicating that he had been flagged down by a taxi cab driver who had Just dropped off two unknown white females, who appeared to be approximately 15 and 17 yoa, at the residence of Epstein, 358 El Brillo Way. The taxi cab drive stated that he picked the females up in West Palm Beach and while traveling to Epstein's residence he overheard the females discussing how much money they would make "dating" in Palm Beach and possible drug use. Off. drove by the residence and observed two vehicles in the driveway, one registered to Epstein, a black Chevy V99YEE and a black Mercedes bearing FL U9080L, which came back as no record found. Det. would also complete a drive by later in the evening and observe a white female enter a small red vehicle, FL . This vehicle is registered to No further information regarding known criminal activity obtained; however, efforts will be made to commence trash pulls from Epstein's residence in the near future. Attached is the Intel report provided by Off. File 300 November 29, 2004 Dot. On November 29, 2004 I reviewed an intelligence report completed by Officer regarding According the report, Alfredo Rodriguez, who is the property manager for 358 El Brillo Way, which is the residence of Jeffrey Epstein, responded to the Police station to report that a suspicious vehicle was parked in the driveway of the residence. Upon arrival, Off. came into contact with who advised that she was there to pick up an envelope from the homeowner (Epstein). Rodriguez stated that Epstein did leave an envelope for land went inside to retrieve it. While waiting, I I received a phone call and stated, "I can't talk, I can't talk, I'm at school, I gotta go" before terminating the call. When questioned who had called I 'advised it was her mother. was advise that she works at Abercrombie and Fitch at the Wellington Green Mall and was introduced to Epstein through a friend who worked there. old that Epstein allows then to come over anytime and use the house and pool. would ask Rodriguez what was in the envelope that was given to I'll and was told it was money for being a message therapist. Rodriguez confided, "off the record, he (Epstein) has many young girls come over for that...there's always a different young girl at the pool or inside with him when he's here." Detectives will attempt contact with in the near future for possible follow-up assistance. Nothing further at this time. CC: Jeffrey Epstein File 2600 January 18, 2005 Det. Persons System Report for : Epstein, Jeffrey E CONFIDENTIAL S0NY_GM_00329841 EFTA 00202567 EFTA01308896 Notes the internet regarding Jeffrey On or about January of 2005, I located an article on Epstein. The article details some of the financial ventures and background regarding Epstein. According the this article, Epstein is a financial manager and only has a clientele with a net worth of 1 billion dollars. Attached is article for informational purposes. File$2600 Det: III 03/31/2005 ce and trash pulls On March 30, 2005, I was asked co begin conducting surveillan reference Detective investigating Epstein as a suspect involved in a sexual was possibly engaging in battery of a 14 year old female. I was advised that Epstein sexual contact with young females. Office Supervisor, March 30, 2005, I made contact with Town of Palm Beach Sanitation March 31, 2005. and requested trash pulls for 358E1 Brillo Way to begin on sanitation employee, March 31, 2005 at 9:20 a.m., I met with Town of Palm Beach seventeen white plastic trash bags from Epstein's property and Jeffrey who collected turned them over to me. through them. I I took the trash bags to the sanitation office were I sifted collected mail correspondence from Armani Exchange addressed to "Jeffrey E. Epstein" notepaper with , a important message at 8:15 p.m. reference Peggy Seagal, U.S notepaper addressed to J.E dated 03/29/05 boarding pass copy for passenger, Janusz Banasiak, Montgomery County, Airways service ID 140140820 for Janusz Banasiak and Maryland Health Department food Photocopies of the trash Ghislaine Maxwell notepaper with names and phone numbers. collected were attached with the supplement. equipped with a video March 31, 2005, at 3:00 p.m., I set up a surveillance vehicle ce vehicle was parked approximat ely fifty foot east monitoring device. The surveillan Epstein's driveway, to monitor and record all vehicle and pedestrian traffic of entering and leaving Epstein's property. from March 31 through April Video surveillance was conducted near Epstein's property 3, 2005. out with new tape. Six Maxell T The video surveillance tapes were regularly changed for intelligen ce. The tapes were filed in the OCVAN -160 VHS tapes wore reviewed office. End of supplement. Filel2600 Det: 04/01/2005 area of 358 El Brillo Way On April 01, 2005 at 9:30 a.m., while parked in the from public works, I observed a white female, who waiting to collect E stein's trash from her Florida driver's license search I conducted I recognized as collected from the trash. I made no contact with from mail correspondence GMC Yukon truck . While parked in the area, I also observed Epstein's well as other vehicles arrive and park across the street from leave the property as workers, appeared to be house the property. The occupants of these vehicle maintenance, and gardeners. employee, Jessie. I sifted through At 9:38 a.m., I collected trash from sanitation ence addressed to Jeffrey Epstein, automotive the trash and collected mail correspond personal documents for Janusz Banasiak and Beata Banasiak as well as records and Persons System Report for: Epstein. Jeffrey E CONFIDENTIAL SONY_GM_00329842 EFTA 00202568 EFTA01308897 Notes "Jeffrey Epstein" notepaper with girls names and times 1-). I also found a three inch purple finger size object which had a broken end. The object appeared to be a broke piece from a sexual toy (Cyclone Vibrator) possibly used for rectal gratification.. The object was photographed for Detective packaged in a bio-hazard evidence bag (possible body fluids) and secured as investigative evidence. Copies of the trash collected were attached with the suppLement. End of supplement. Filet2600 Det: III 04/05/2005 On April 05, 2005 at 9:18 a.m., I collected trash from sanitation employee, Jessie. I transported the trash bags back to the sanitation site, where I sifted through the trash bags and collected mail correspondence addressed to Jeffrey Epstein as well as notepaper (Important Message) names and telephone numbers. The following aro items of paper collected from Epstein's trash. Joanne G. ( blank piece of white paper black paper ( black paper ( David 1 MSN Hotmail web page with email address The following items wore documented for Detective IIIIIII investigation prior to disposal. End of supplement. File: 2600 Det: 04/21/2005 During the month of April 2005, trash pull were conducted at 358 El Brillo Way to gather further intelligence related to Detective investigation of Jeffrey Epstein possibly being sexually involved with underage girls. Trash from Epstein's residence was collected by Palm Beach Sanitation employee, Jessie. The trash bags from Epstein's were turned directly over to me upon Jessie driving away from the property on most days, however if I was unable to met with Jessie, he would leave the Epstein's trash bags at a designated area at the sanitation office. All trash collected from Epstein's which included, mail correspondences addressed to Jeffrey Epstein, and other household members, notepad papers, with names, telephone numbers, notes and a three inch purple object that appeared to be part of a sexual toy were turned over to Detective The six Maxell T-160 vhs video tapes collected from the surveillance remained in my custody. End of supplement. Filet2600 Det: III 06/14/2005 Persons System Report for: Epstein, Jeffrey E CONFIDENTIAL SONY_GM_0032984a EFTA 00202569 EFTA01308898 Notes On June 14, 2005, Detective contacted me and advised that the airplane belonging to Jeffrey Epsteinii,1158 El Brillo Way was parked at Palm Beach International Airport. Detective requested that I begin trash pulls for the purpose of gather intelligence. I made contact with Tony Higgins of Palm Beach Sanitation and requested that on June 15, 2005, all of Epstein's trash be collected and transported to the sanitation department. End of supplement. File 100 September 12, 2005 Det. On or about September 11, 2005, I was arrested for possession of marijuana in the north end of the island during a traffic stop by Ott. Soo case number 05-1263 for further information. Previous intelligence indicates that) may have been paid money for sexual acts from Jeffrey Epstein. allillwould have been under the age of 18 at the time this act would have allegedly taken place. On September 12, 2005 I made telephone contact with at phone numbe VIIII]]stated that she was willing to speak with me about a resident on t e island involved in "disgusting activity". indicated that this person was of high influence and had 6 to seven assistants working for him. I stated that she has heard he also has police officers working for him. 'discussed her concerns about the marijuana arrest and stated that she is know living in outside of Jacksonvilld and would not be able to assist police. IllIpindicated that she would come to the police department today; however, it was determined by Capt. that she should be more thoroughly interviewed at a later date. It should be noted that Epstein's name was not mentioned during the entire conversation andallinwas instructed not discuss this matter with anyone else. indicated that she last spoke with Epstein through e-mail approximately 2 weeks ago. was further asked to save/document any future correspondence. Det. Bureau notified of III. information. Sgt. 05-368 2600 September 21, 2005 On Wednesday September 21, 2005 Detective requested that the trash at 358 El Brillo Way be collected for evidentiary purposes. I contacted Sanitation Supervisor Tony Higgins at ext 7041 and requested that the trash be collected while an investigator observes the collection. He then contacted Jeff Williams, who is the employee on that route and informed him to contact me prior to picking up the trash. At 9:30 a.m., I had not received a call from Mr. Williams so I responded to the area to wait for him to arrive. As I approached El Brill° Way, I observed Jeff Williams driving his collection vehicle eastbound on El Brillo to South County Road. I met with Williams on South County Road and collected four bags from the back of his truck. I then responded to the Police Department and informed Detective that I would search through the trash. He then met with me in the basement area an assisted in the search for items. Several items of paper with information either typed or handwritten was taken into evidence. Persons System Report for: Epstein, Jeffrey E CONFIDENTIAL SDNY_GM_00329844 EFTA 00202570 EFTA01308899 Notes Contact was made with Supervisor Higgins, to request that trash be collected again on Friday September 23, 2005. Investigation Continuing. File 2600 September 23, 2005 Det. On or about September 23, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. for follow-up. No further action taken. File 2600 September 23, 2005 Det. On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jessie Jones. I observed Jones enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident and notified Det. to that affect. On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jesse Jones. I observed Jones enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty sanitation truck. I then followed Jones to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All documents of evidentiary value were removed and turned over to Det. for follow-up. No further action taken. On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker Jeff Williams. I observed Williams enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. I then followed Williams to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 7 white in color plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Also located was a broken piece of a hard Persons System Report for FpsPip Jeffrey F CONFIDENTIAL SDNY_GM_00329845 EFTA_00202571 EFTA01308900 Notes plastic or clear acrylic stic k, which was shaped with commonly used as a sexual small ridges. This device is toy which is inserted into stimulation. This item, the vagina or anus for along with all documents of and turned over to Dot. evidentiary value were remo for follow-up. ved On or about Tuesday October 4, 2005 at approximately El Brillo and met with PB 0928 hours, I responded to Sanitation worker Jeff Will 358 enter the driveway of 358 iams. I observed Williams El Brillo and remove several place the contents into the plastic bags of trash and side well of the sanitati truck is separate from the on truck. This side of the rear of the truck and does other Crash. not come into contact with I then followed Williams to a predetermined location truck. The trash was tran and seized the trash from sported to the Palm Beach the sifting through its cont Police Department where I ents. There were a total began which were tied at the of 2 white in color plastic top. Each of the bags containe bags correspondence for 358 El d documentation and Brillo and Jeffrey Epstein. value were removed and turn All documents of evidenti ed over to Det. ary for follow-up. File 2600 October 5, 2005 Det. PBPD 5-3 On or about Wednesday Octo ber 5, 2005 at approximatel 358 El Brillo and met with y 0928 hours, I responded PB Sanitation worker Jeff to enter the driveway of 358 Williams. I observed Will El Brillo and remove seve iams place the contents into the ral plastic bags of trash bed of the sanitation truc and k. I then followed Williams to a predetermined location truck. The trash was transpor and seized the trash from ted to the Palm Beach Poli the sifting through its contents ce Department where I bega , with the assistance of n total of 2 bags, one of whic Det. . There were a h was white in color and the other was a black in tied in a knot at the top, and color bag, which containe two along with loose debris. Each d white in color trash bags of the bags contained document correspondence for 358 El ation and Brillo and Jeffrey Epstein. value were removed and turn All documents of evidentiary ed over to Det. for follow-up. File 2600 October 5, 2005 Det. PBPD 05-368 On Friday, October 7, 2005 at approximately 0923 hours, I and met with PB Sanitation work responded to 358 El Brillo er Jeff Williams. I observed driveway of 358 El Brillo and Williams enter the remove several plastic bags contents into the bed of an of trash and place the empty sanitation truck. I then followed Williams to a predetermined location truck. The trash was transpor and seized the trash from the ted to the Palm Beach Police sifting through its contents Department where I began . There were a total of 3 bags in color and tied in a knot , one of which was white at the top, and the other One bag contained document two bags were black in color. ation and correspondence copied and given to Det. for Jeffrey Epstein, which was for informational purpose. white piece of stationary It is described as a with "Jeffrey E. Epstein" type on the letter was, "Luba d at the bottom. Handwritten Sunday 100 (1:00), Improve Satu Flamingos Beach". Nothing rday 1500 Bay Road Miami of evidentiary value was located. Persons System Report for: Epstein, Jeffre yE CONFIDENTIAL SDNY_GM_00329846 EFTA_00202572 EFTA01308901 Notes File 2600 October 5, 2005 Det. PBPD 5-3 On Monday, October 10, 2005 at approximately 0943 hour Brillo and met with PO Sani s, I responded to 358 El tation worker Jeff Will the driveway of 358 El Bril iams. I observed Williams lo and remove a plastic enter the bed of an empty sani bag of trash and place it tation truck. into I then followed Williams to a predetermined loca truck. Tho trash was tran tion and seized the trash sported to the Palm Beach from the sifting through its contents Police Department where . There was ono white I began tied in a knot at the top. in color plastic bag whic The bag contained nothing h was of evidentiary vaLuo. NOTE: AS OF 10/11/2005 ALL NEW FILED SUPPLEMENTS FOR JEFFREY EPST 2600-8 EIN SHOULD BE Links Activities Addresses Aircraft Aliases Arrests and Charges Arrest Warrants Associates - 2 Businesses Cases Gangs and Groups Locations Media Telephone Numbers Vehicles Watercraft Persons System Report for: Epstein, Jeffrey E CONFIDENTIAL SONY_GM_00329847 EFTA_00202573 EFTA01308902 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B.B., Plaintiff, v. CASE NO. 502008CA0371119XXXXMB AB JEFFREY EPSTEIN, Defendant. NON-PARTY TOWN OF PALM BEACH POLICE OFFICERS' MOTION TO QUASH SUBPOENAS AND/OR MOTION FOR PROTECTIVE ORDER Non-parties, former Town of Palm Beach Chief of Police Michael Reiter, Captain George le Detective Joseph , Detective Detective a, and the Town of Palm Beach Police Department Recor d Custodian (collectively 'Town of Palm Beach Police Office rs"), hereby move to quash the subpoena or for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) directing that discovery sought by the civil subpoenas for deposition issued by Plaintiff, B.B , and the cross-notices with subpoenas for deposition duces tecum issued by Defendant, JEFFREY EPSTEIN, in the underlying action, attached as Composite Exhibit A, not be had or that the discovery may be had only on specified terms. In further support, the Town of Palm Beach Police Officers state as follows: SUMMARY OF ARGUMENT Al issue here Is whether certain documents and assoc iated testimony sought by Mr. Epstein, including personal cell phone record s, calendars and diaries and surveillance information, constitute public records subjec t to disclosure or are statutorily CONFIDENTIAL SDNY_GM_00329848 EFTA_00202574 EFTA01308903 protected from disclosure under Florida's Public Records Law, Section 119.071 Fla Stat., and if the documents and testimony sought consti tute private records of the individual officers not otherwise statutorily protected, wheth er Mr. Epstein's requests are improper as not likely to lead to the discovery of admissible evidence and overly broad. The Town of Palm Beach Police Officers respectfully submit that the Epstein duces tecum constitutes a fishing expedition into the private and confidential matters of these non-parties that do not constitute matters of public record under the Florida Public Records Law and bear little relationship to the issues in this civil litigation. The duces tecum is intended solely to harass these non-parties in advan ce of their depositions. As set forth in detail below, the Epstein duces tecum seeks a broad range of statutorily protected information not just regarding these law enforc ement officers and the crime victims associated with Mr. Epstein's investigation , but a broad range of protected information regarding other crime investigations undert aken by the Town over a 5-year period. BACKGROUND By this and related suits,' an alleged minor victim of lewd acts and/or prostitution has filed a civil suit against Mr. Epstein for sexual battery and intentional infliction of emotional distress. Mr. Epstein was the subject of an investigation by the Town of Palm Beach Police Department in 2005 and 2006, which investigation resulted in the issuance of a Probable Cause Affidavit for Mr. Epste in and others in May 2006. ' A number of related cases are pending against Mr Epstein in Florida slate and federal courts 2009, the related federal court cases were consoli In May dated before Judge Kenneth Marra for discovery procedural purposes. Judge Marra directed and that witnesses common to the multiple cases deposed only once. Undersigned counsel understands would be from conversations with counsel for Mr. Epstein and the Plaintiff in this case that counsel in the related state court actions have acted in accordance with Judge Marra's order to depose witnesses commo n to the stale and federal cases only once 2 CONFIDENTIAL SDNY_GM_00329849 EFTA_00202575 EFTA01308904 Following the issuance of the Probable Cause Affidavits, the Town's investigation ceased and the matter was referred to the appropriate state and federal law enforcement authorities. Mr. Epstein ultimately pled guilty and was sentenced by the State Attorney to incarceration for a period of 12 months in county jail and designated a sex offender. Counsel for Plaintiff first subpoenaed the Town of Palm Beach Police Officers for deposition in October 2009. Those subpoenas did not include any duces tecum. Thereafter. Epstein's counsel cross-noticed the depositions and served the Town of Palm Beach Police Officers with subpoenas duces tecum the Epstein duces tecums). With the exception of the Epstein duces tecum issued to the Records Custodian, which additionally seeks state grand jury testimony (No. 7) and personnel records of Chief Reiter and Detectives and (No. 19), the Epstein duces tecum served on the Town of Palm Beach Police Officers are identical. Epstein's extremely broad document requests to the Town of Palm Beach Police Officers are detailed in more than twenty (20) separate requests, many with multiple subparts. Among other things, the Epstein duces tecum requests the following: • Video and Physical Surveillance: Any and all logs, pictures, videos, digital information, reports, memoranda or notes, and any record of expenditure, which relate to video or physical surveillance of Mr. Epstein, his residence or his visitors (or, with regard to physical surveillance, any individual believed to be a potential witness or co-conspirator) from January 1, 2004 to the present (Nos. 11-12); • Cell Phone Records: All cell phone records, both official cell phone and personal cell phone, used by the Police Officers from January 1, 2004 through the present (No. 15); • Calendars or Diaries: All calendars or diaries, electronic or hard-copy kept from October 1, 2004 through and including today (No. 16). 3 CONFIDENTIAL SDNY_GM_00329850 EFTA_00202576 EFTA01308905 LEGAL ARGUMENT Florida Rule of Civil Procedure 1.280(c) allows a person from whom discovery is sought to move for an order to protect that person from annoy ance, oppression or undue burden by directing "(1) that the discovery not be had; (2) that the discovery may be had only on specified terms and conditions ... . that certain matters not be inquired into, or that the scope of the discovery be limited to certain matters. . Rule 1.280(14(1) provides that parties "may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter of the pending action. " As federal courts have observed in construing identical language under the Federal Rules of Civil Procedure, 'requested information is not relevant to 'subject matter involv ed' in the pending action if the inquiry is based on the party's mere suspicion or speculation? Micro Motion, Inc. v. Kane Steel Co.. Inc., 894 F.2d 1318, 1325-26 (Fed. Cir. 1990). 3 "A trial court has authority to prevent discovery which it believes is a mere fishing expedition calculated for harassment" Sugarmill Woods Civic Association. Inc. v. Southem States Utilities 687 So. 2d 1346, 1351 (Fla. 1st DCA 1997) Where it has been affirmatively established that the discovery sough t is neither relevant nor will lead to the discovery of relevant information, a trial court has discretion to deny the irrelevant discovery. Allstate Insurance Company v. Langs ton 655 So. 2d 91, 95 (Fla. 1995): Residence Inn by Marriott v. Cecile Resort, Ltd. 822 So. 2d 548, 550 (Fla. 5th DCA 2002) (agreeing that carte blanche discovery of materi al Is impermissible and noting that the record was insufficient regarding the releva ncy of the requested documents). 3 Florida courts look to the federal rules and decisions for guidance in interpreting Florida's civil procedure rules" so as to harmonize the Florida and federal rules. Gleneaole Shit) Montt. v. Leonda 602 So 2d 1282, 1283-84 (Fla 1992) kos , 4 CONFIDENTIAL SDNY_GM_00329851 EFTA_00202577 EFTA01308906 A. Information Regarding Crime Victims; Victims of Sexua l Offenses; Minor Victims As a threshold matter, the Town states that in accordance with its obligations under Section 119.07 of the Florida Public Records Law, any documents and testimony provided in response to the Epstein duces tecum will be redacted and/or limited to protect those matters excepted from disclosure including, but not limited to, the home addresses and telephone numbers of the law enforcement personnel and any identifying information regarding the victims. Such redact ion is necessary because of the broad range of criminal intelligence and investigative information regarding minor victims of sexual offenses under Florida Statutes Chapter 794 and/or 800 sought by the Epstein duces tecum. Such information is carefully protec ted under the Public Records Law. Fla. Stat. § 119.071(2)Q) (excepting from disclos ure any document that reveals the identity, home or employment telephone number, home or employment address, or personal assets of the victim of a crime, including the crime of sexual battery, and identifies that person as the victim of a crime); Fla. Stat. § 119.071(2)(h)1 b (excepting any information which may reveal the identity of a person who is a victim of a sexual offense, including a sexual offense proscribed in Chapt ers 794 and 800). Likewise, the Town of Palm Beach Police Officers will not provide testimony or documents that reflect their own exempted personal inform ation including their home addresses, telephone numbers and social security numbers. Chapter 119.071 of the Florida Public Records Law specifically exemp ts from disclosure personal information belonging to law enforcement personnel and their families as well as personal information for crime victims, including minor victims and victims of sexual offenses. "The home addresses, telephone numbers, social securi ty numbers and photographs of 5 CONFIDENTIAL SDNY_GM_00329852 EFTA_00202578 EFTA01308907 active or former law enforcement personnel" are exempt from statutory disclosure provisions Fla. Stet § 119.071(4)(d)1.a; Atty. Gen. Op. 2007- 21 (Apr. 25, 2007) (sworn officers of a police department fall within this exemp tion as 'law enforcement personnel"). Along with the places of employment, the same information is protected relative to the spouses and children of such law enforcement personnel. B. Private or Personal Information Belonging To the Town of Palm Beach Police Officers The Epstein duces tecum seeks a number of docum ents including all cell phone records, calendars and diaries used or created by the Town of Palm Beach Police Officers from January 1, 2004 to the present. These requests clearly encompass personal records not covered by the Public Records Law. Moreover, the requests cover a five-year time period, are not limited in any way to matters involving Mr. Epstein and are therefore overly broad and not likely to lead to the discovery of admissible evidence. 1. arsons: Calendars and Diaries (Request No. 16) Mr. Epstein is not entitled to obtain "[ajll calendars or diaries" kept by the Town of Palm Beach Police Officers from January 1, 2004 to the present because these documents are not public records subject to disclosure and because these records may contain statutorily excepted information regard ing the law enforcement personnel themselves and other criminal investigations. Sectio n 119.011(1), Florida Statutes, defines "public records" to include. All documents, papers, letters, maps, books , tapes, photographs, films, sound recordings, data processing software, or other material, regardless of the physic al form, characteristics, or means of transmission, made or received pursuant to law or ordinance or in connection with the transaction of official business by any agency. (emphasis added) 6 CONFIDENTIAL SDNY_GM_00329853 EFTA_00202579 EFTA01308908 Documents and other information that is not "made or receiv ed" in connection with the "transaction of official business' are not public records subjec t to disclosure. Times Publ'q Co. v. City of Clearwater, 830 So 2d 844, 847 (Fla. 2d DCA 2002) (holding private or personal e-mails stores in government compu ters do not automatically become public records). Personal calendars and diaries do not constitute public record s because they are not actions of government, but merely personal notes or work papers created for the convenience of the individual keeping the calendar. Florida courts have consistently held that under Chapter 119, public employees' notes to thems elves and designated for their own personal use in remembering certain things do not fall within the definition of "public record." The Justice Coalition v. First DCA Nomin ating Comm 'n 823 So. 2d 185. 192 (Fla. 151 DCA 2002) (citing t.opez v. State 696 So. 2d 725 (Fla. 1997); Times Pub. Co. v. City of St. Petersburg, 558 So. 2d 487, 491-92 (Fla. 2d DCA 1990) (notes which "serve no governmental function" but are 'merely the personal tools of recollection of the writer' are not public records) As one court has observed, ... the cases consistently hold that personal notes, as well as telephone messages and daily appointment calendars are not public records. This is because they are generally created solely for the individ ual's convenience or to refresh the writer's memory, are maintained in a way private purpose, are not circulated or intended for distrib indicating a ution within agency channels, are not under agency control, and may be discarded at the writers sole discretion. Yacobellis v. City of Bellingham 780 P,2d 272, 275-76 (Wash. App. 1989) (collecting cases). See also Bur. of Nat'l Affairs v. U.S. Delft. of Justic e 742 F.3d 1484 (D.C. Cir. 1984) (holding that personal appointment materials, such as calendars and daily agendas for the convenience of Assistant Attorney Gener al, are not agency records 7 CONFIDENTIAL SDNY_GM_00329854 EFTA_00202580 EFTA01308909 under the Freedom of Information Act)" Union. United Auto., Aerospace & Agricultural Implement Workers of Am. v. Voinovich 654 N.E.2d 139, 142-43 (Ohio App. 1995) (holding governors personal calendars and appointment books were not "public records" subject to disclosure under public record s statute where calendars and appointment books were created and maintained solely for governors personal convenience, were not circulated within office for any officia l purpose, were not under control of governors office, could be discarded at any time, and did not serve to document any official activities or functions of govern or); Courier-Journal v. Jones 895 S.W.2d 6 (Ky. App. 1995) (same). 2. Cellular Telephone Records (Request No. 15) Mr. Epstein's request for lajll cell phone records" from 2004 to the presen1 is similarly improper as it not only seeks private, non-p ublic records, but statutorily protected information regarding the law enforcement officers who made the calls and the persons to whom calls were made including, but not limited, to family members. crime victims and confidential informants. As with person al or private e-mails stored in government computers, private phone calls that were not created or received in connection with official business do not become public records simply because they are made on a government issued telephone. See Media Gen'l Operation. Inc. v. Feeney 849 So. 2d 3 (Fla. 15' DCA 2003) (private or personal cellular telephone calls of five staff employees of House of Representatives were not public records)' Times Publics Co., 830 So. 2d at 847. See also State v. Ohio Atty. Gen. 910 N.E.2d 504, 677-78 (Ohio Ct. App 2009) (holding cell phone number of state troope r was not a "public record" subject to disclosure under public records act); Gannett N.J. Partners v. Ctv. of Middlesex 877 8 CONFIDENTIAL SDNY_GM_00329855 EFTA_00202581 EFTA01308910 A 2d 330 (N.J. Super. Ct. App. Div. 2005) (finding news organization not entitled to disclosure of the telephone billing records of county officials under the state's open public records act, observing that public officials and persons they talk to have a right to confidentiality, public records act excepted from "public records" the "unlisted telephone number' of any person and there was no practical way to prevent disclosure of such numbers, and voluminous request for 12 months worth of records would disrupt agency operations). C. Surveillance Techniques, Procedure or Personnel The Town of Palm Beach Police Officers do not dispute that if they possessed any surveillance tapes or photographs of Mr. Epstein during the time of the investigation in 2005 and 2006, which they do not, that such evidence may be subject to disclosure if it did not identify the victims of contain any other statutorily protected information. However, Mr. Epstein is not entitled to any testimony or documents regarding the techniques, procedure or personnel involved in any video or physical surveillance of Mr. Epstein. See Epstein duces tecum, Nos. 11-12. Any information revealing law enforcement surveillance techniques, procedures or personnel is clearly exempt from public inspection under the Public Records Law. Fla. Stat. §119.071(2Xd), referring to Section 24(a), Art. I, Fla. Const. D. Epstein's Requests are Unduly Burdensome Finally, even if subject to disclosure under the Public Records Law, Mr. Epstein's request for la]ll cell phone records" and "(alit calendars and diaries", whether in hard- copy or electronic format, for the Town of Palm Beach Police Officers for a 5-year period is not only overly broad and not likely to lead to the discovery of admissible 9 CONFIDENTIAL SDNY_GM_00329856 EFTA 00202582 EFTA01308911 evidence, it is unduly burdensome. In addition to the time needed to initially gather these records, considerable effort would be required to review them to determine whether they contain statutorily protected information excep ted under Section 119.071 of the Public Records Law and to thereafter redact that information in order to protect the identities of crime victims, undercover personnel, confid ential informants, etc. which bear absolutely no relation to this case and are entitled to have their privacy protected. The Town of Palm Beach Police Officers respectfully request that should the Court overruled its other objections to the requested discov ery, that they be given the opportunity to provide evidence in support of their claim of undue burden. WHEREFORE, the Town of Palm Beach Police Office rs respectfully request that the Court enter an Order pursuant to Florida Rule of Civil Procedure 1.280(c) directing that the Epstein duces tecum be quashed as set forth herein and that the Court grant the Town of Palm Beach Police Department all other relief deemed just and proper under the circumstances. 10 CONFIDENTIAL SDNY_GM_00329857 EFTA_00202583 EFTA01308912 I HEREBY CERTIFY that a true copy of the foregoing instrum ent has been furnished by facsimile and United States mail to Theodor J. Leopold, Esquire and Spencer T. Kuvin, Esquire, Leopold-Kuvin, P.A., 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400, West Palm Beach, Florida 33401-5012; and Robert D. Critton, Jr., Esqui re, Burma n, Critton, Luttier & Coleman, LLP, 515 North Flagler Drive, Suite 400, West Palm Beach, Florida 33401, this 20th day of November, 2009. JONES, FOSTER, JOHNSTON & STUBBS, P.A. 505 South Flagler Drive, Suite 1100 Post Office Box 3475 West Palm Beach, Florida 33402-3475 Telephone: 561-659-3000 Facsimile: 561-650-0465 By 7,4'er / John C. Randolph Florida Bar No. 129000 irandolpheiones-foster.com Cf1Documents and SettingslSSMSJS_DOMAIMLoc al Settingsifemporary Internet FiestOLK3U6V6 665-motion protective order (2) DOC 11 CONFIDENTIAL SDNY_GM_00329858 EFTA_00202584 EFTA01308913 Date: 9/13/07 PALM BEACH POLICE DEPARTMEN Time: 14:03:07 T Page: 1 Incident Report Program: CMS301L Case Number . : 1-03-0014 98 SPECIAL NOTES : Occur From Date: 10/05/03 0824 Occur To Date : 10/05/03 Report Date . : 10/05/03 0824 0845 Day Of Week . : Sunday Common/Location: 358 EL BRILLO WY City • PALM BEACH, FL Location Type : RESIDENCE -SINGLE FAMILY Beat Assignment: SHIFT 2 Dept Class . . : BURGLARY Case Status . : EXCEPTION RESIDENCE Map Reference Report Officer 10 ALLY CLEARED Case Status Supervisory Dt.: Dt 10 15 Entry Date Names' . : PP RONALD 10/05/03 RO, LAURA 10/06/03 Vehicles? . . : Property? . . Narrative? . . : Offenses? . . Interfaces? . : Related Cases? P R PERTY INFORMATION Case number . : 1-03-0 # 1 ****w**************** 01498 Category . . . **MISC OR UNFOUNDED PROP ** Description PISTOL Serial number Color Model Make CLOCK Property type : HANDGUN UCR Prop Type : FIREARMS Insured by . . Insured' Value NCIC number . 1,000.00 Recovered Date : 0/00/0 Recovered by . 0 Recovery value : 0.00 Street number : City Drug? Property Msg . : Document? . . : Property Seq . : • * * * ***** PROPERTY IN FORMATION Case number . 1-03-001498 # 2 Description . : U.S.CU Category . . : *STOLEN/RECOVERED* RRENCY Color Serial number : Model Make Property type : CUR UCR Prop Type : CURRENCY, RENCY/NEGOTIABLE NOTE, ETC. Insured by . . Insured' Value NCIC number . 2,700.00 Recovered Date : Recovered by . Street number : Recovery value 2,700.00 City Drug? Property Msg . Document? . . Property Seq . P E R S O N REPORTI Case Number . : 1-03-0 N G INFO - # 1 01498 Last Name . . : Street Number : 301 E 66TH ST 10N City • NEW YORK, NY 10021 Birth Date/Age : 24 Employer? . . : Occupation . . : PERSON AL ASSISTANT Oper Lic No. . : 241534676 Home Phone No. : HA Sex • Race • White weight Height • 508 0 Other Phone Nbr: CONFIDENTIAL SONY_GM_003291359 EFTA_00202585 EFTA01308914 Date: 9/13/07 PALM BEACH POLICE DEPARTMEN Time: 14:03:07 T Page: 2 Incident Report Program: CMS301L 1-03-001498 (Continued) P E R S O N REPORTING Case Number . : 1-03-0014 I N F O - # 2 98 Last Name Street Number : 358 EL FRIEDMAN, MICHAEL DAVID BRILLO WY City • PALM BEACH, FL 000033480 Birth Date/Age : 10/27/197 0 32 Employer? Occupation . . : HOUSE . : MANAGER Oper Lic No. . : U6084172 Home Phone No. : CA Sex Race White Male Weight Height 601 190 Other Phone Nbr: P ERSON REPORTING Case Number . : 1-03-0 INFO _ # 3 ********* 01498 Last Name Street Number : 358 EL BRILLO WY City PALM BEACH, FL 000033480 Birth Date/Age 11/03/1974 28 Occupation . . Employer? . . : HOUSE MANAGER Home Phone No. Oper Lic No. . : D5571369 CA Sex Race Female Weight Height 504 135 Other Phone Nbr: PERS O N R E P ORTING Case Number . : 1-0 I N F O - # 4 3-001498 Last Name . . Street Number : 22 AVE COTRIN, VALDSON VIEIRA NUE FOCH City PARIS, Birth Date/Age 0/00/0000 0 Occupation . . Employer? . . : Home Phone No. : 561/00 Oper Lic No. . : 0-0000 Race Sex Weight Height 0 • 0 Other Phone Nbr: 561/00 0-0000 VICTIM I N FORMATION Case Number . : 1-03-0 - # 1 ****** Street Number : 358 01498 Prompt valid in: EPSTEIN, ************** EL BRILLO WY JEFFREY EDWARD City • PALM BEACH, FL 000033 Birth Date/Age : 1/20/1 480 953 50 Employer? Occupation . . : BANKER . : /SELF Oper Lic No. . Home Phone No. 090443348/VIRGIN IS. Sex Race White Weight Height • o Misc. ID# . . 600 Be On Look Out?: Victim Type . Other Phone Nbr: Residency Sts : Residency Type : Can Identify . File Charges . : Injury Extent : Victim Sobriety: Injury Type 2 : Injury Type 1 : Med Treatment : Hospital ID . Phys Last Name : Phys First Name: ***EMPLOYER INFORMATI Case Number . : 1-03-0 ON*** 01498 Employer Name Address . . . : CONFIDENTIAL SDNY_GM_00329860 EFTA_00202586 EFTA01308915 Date: 9/13/07 PALM BEACH POLICE DEPARTMENT Time: 14:03:07 Page: 3 Incident Report Program: CMS301L City/State/Zip : PALM BEACH, 1-03-001498 (Continued) FL 000033480 Phone Number . : OTHER PERSON Case Number . : 1-03-0014 INFORMATION - # 1 ***ler.*** 98 Las t Name Street Number : 1515 SO FLA . : ALESSI, MARIE GLER DR. #1901 City • WEST PALM BEACH, FL 33407 Birth Date/Age : 10/27/194 6 56 Employer? . Occupation Home Phone No. : 561/000-0 Oper Lic No. 000 Race Sex Female White Weight Height 0 0 Person Type Other Phone Nbr: 561/000-0 : OTHER PERSON 000 *********OTHER PERSON Case Number . : 1-03-0014 INFORMATION - # 2 98 Last Name . . : ALESSI, JOH Street Number : 525 SO N SEQUOIA APT. A City WEST PALM BEACH, FL 33409 Birth Date/Age : 4/14/1975 Occupation . . 28 Employer? . . Home Phone No. : 561/000-0 Oper Lie No. 000 Race Sex Male White Weight Height 0 0 Person Type . : OTHER PER Other Phone Nbr: 561/000-0 SON 000 ************************** **NARRATIVE Original Report LO # 1 Reported By: Entered By.: D. 10/05/03 10/06/03 On Sunday 10/5/03 at app to a burglary at 358 El rox ima tel y 0824 hours, I was dispat Brillo Way. Upon arriva ched reporting party/victim Jef l, I met with frey Epstein, white male, Epstein advised he and his dab/012053. personal assistant female, arrived in the residence , white 10/3/03. Epstein advise on Fri ay evening, d that on Saturday evenin his briefcase at his des g 10/4/03, he left k and went to bed at app Epstein said when he lef roximately 1230 am. t his briefcase, it contai $5000 V.S. currency. ned approximately kept in a white envelope advised the case was in ins $100 bills and approximately 0715 hours on ide the briefcase. Epstein stated at desk, he noticed the bri Sun day, 10/5/03, while sittin efcase had been opened and g at his was missing. Epstein bel some of the cash ieved approximately $3500 briefcase. Epstein advised was taken from the tha sequential or recorded. Eps t he did not know if the cash was tein further advised a bla was taken from the bookshelf ck Glock handgun he suspected cash had bee located behind his desk. n taken from his briefcase Epstein advised occasions while he was in on two other town for the weekend. The Labor Day weekend Aug. 30- first was over Sept 1, 2003. The second in mid September, 2003. Eps time was a weekend incidents because he was tein stated he did not rep ort these not sure the money was acc Possible footage of the inc ounted for. ident may exist. I next who advised she went to bed met at approximately 1130 pm on with 10/4/111,11 CONFIDENTIAL SDNY_GMJ)0329861 EFTA_00202587 EFTA01308916 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 4 Program: CMS301L did not hear or se 1-03-001498 (Continue e anything unusual thr d) morning of 10/5/03. ough the night or on Cotrin, the resident the bed at approximately chef advised that he 1030 pm on 10/4/03 went to approximately 6:20 am and began work at on 10/5/03. Cotrin or hear anything unu stated that he did not sua side of the property. l from the staff residence locate don see are the house manage residence at approx I next spoke to Mike rs. Mike stated tha mairimpi and t he went o e sta the east who imately 8:30 hours on approximately 11:30 10/4/03 and got up pm same night to mov at garage. Mike said e he returned to the res the Mercedes into the am on 10/5/03 but did not notice anythi idence at a roximately 6:20 that she checked the ng unusual. exterior of the reside stated on 10/4/03 as part of nce at approximatel he y no one and everythin r dut ies. g appeared in or er stated at that time, 7:30pm . she saw main house at approx 8:30 on 10/5/03. It have been employed as imately 11:30 pm an should be noted tha dPM t Mik stated she left the at approximately the house managers sin e and them, the live on si ce 9/24 0 . riot o te was unsure of the las house managers were Patrick and Evelyn t name. Patrick Eve , Epstein Brillo approximately lyn were employed at 9 months. Prior to 358 El Alessi who was emp the house manager loyee at 358 El Bri was John Epstein signed an llo approximately 10 affidavit of rosecu years. report. Crime Scene tion, it is attach ed scene. Det. O manager responded andproce to this l. also respon e ssed the for further in poarmation. Officer . See Det. neighborhood canvas responde an conduc report which is also att ted a be noted that Epstei ached to this report n will contact Pal . It should the serial number m of the stolen handgu Beach Police Department with FCIC. n so that it may be entered into ******************** ********NARRA GREENE TINIE # 2*************** Reported By: ************ Entered By.: 10/06/03 On 10/05/03, at 10 10/06/03 00 hours, I respon reference a burgla ded to 358 El Bril ry that had occurr lo the night. Upon my ed at the residence Way arrival, I met with during verbally identified the homeowner who himself as Jeffrey Epstein, DOB 01/20/ Epstein told me tha 53. t over the last cou has come into town, ple of months, whe he has money he had n he bag, has turned up left in his carry missing. Epstein on amount of money in sai the carry on bag on d he wasn't sure of the and thought that he any specific incide possibly had mispla nt told me that he had ced the money. Eps purchased a spy cam tein Okeechobee Blvd. and era from a store on clock in his office had set up the camera which was in facing the briefcase a Epstein then placed with the money in bill increments and $4, 000 . in U.S. currency, one it. left the bag on hi hundred dollar when he is in town. s desk as he always Epstein said that does camera system mon he went to bed wit itoring the bag and h the and twice to have desk area, only to $100. missing from wake up the bag and the sus pects CONFIDENTIAL SONY_Std_00329862 EFTA_00202588 EFTA01308917 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 5 Program: CMS301L image on his comput 1-03-001498 (Co er hard drive. It sho were thirteen one hun uld be noted that thentinued) dred dollar bills re and that nothing el stil se in the house appear l in the white envelope suspect. ed to be disturbed by the Epstein took me to the monitor that was dis computer room where playing a still frame he showed me a computer computer indicated a of the suspect. The time of 0428 a.m., the office area, wal when the suspect came ked behind the des into then opened the cent k, er drawer to the de opened the hand bag, and the suspect was fam sk. It appeared as iliar with the house though told me that he did and the desk. Epstei not know who the sus n but thought it mig pect in the photo ht be his former hou was and shape. Epstein seman because of his also pointed out th size video was wearing moc at the suspect in th casin type shoes li e did due to his back ke his former housem injury. The suspec was 5'10" in height, t was a white male whan 250 lbs., wearing o and a hat. Epstei tan pants, white shi n provided me with rt, information which was the former houseman' Juan P. Alessi, DOB s , living at , West Florida. I advised Epstein that I would need surveillance video fro to obtain a copy of m his computer har the have in hands. Eps d drive in order to tein told me that knowledge of the sys he had limited wor tem but he would con king had installed the tact the company who system and have the Epstein told me he m make a copy by Mon would call when he day. had more informati on. Epstein took me to the desk where the me that he believed carry on bag was an d told into the house fro that the suspect might have gained m the sliding glas entry of the house but no s doors on the sou t th side personally locked all the west aide of house because he had It is believed that the sli der s on that side of the suspect also the house. same sliding door left the house by that was unlocked the or indication of for as there were no pry ced entry into the marks me the bookcase beh ind the desk where house. Epstein also showed handgun between the he kept his Glock 9 not supply me with books which was now missing. Epstei mm the serial number n could time but advised for the handgun at he would contact Ga this Blvd. to obtain the tor Gun on Okeechobe information. e Crime Scene Manage r Gr collected the envelo eg processed the crim e scene and pe that t e money had been taken out of. Officer conducted a neighb produce any new inf orh ood ormation as most of canvas and failed to home at this time. the neighbors were not Officer collected the names included of the house guests , DOS which , DO , who is from Slovak , who is a massage ia, therapist from CONFIDENTIAL SONY_GM_0029103 EFTA_00202589 EFTA01308918 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 6 Program: CMS301L California. All the 1-03-001498 (Conti subjects advised that nued) anything during the they hadn't heard night. Officer also collected the nam were MicilM illiedman es of the live in emp , DOB , Rosilee Friedman, loyees Ralli and Chef Valdwon otr that they hadn't hea in, DOB DOB . All the subjects rd anythingl ial l the night. The criminal history sea other than being a nat rch of Alessi revealed no criminal histor full name was Juan uralized United Stat y Patricio Alessi Munoz. es citizen and that his ATTN POLICE CLERKS; Please show a stolen currency as **$2,7 value for the U.S. 00.** Please show a 9 mm handgun as $1, stolen value for the 000.** Glock Invest.Cont. ******************* ************** GREENE **** # 3 *********:****** Reported By: *********** Entered By.: At 8:42 a.m., Sund ay by the communicatio morning, 10/05/03, I was notified at n unit of the Palm home burglary had been Beach Police Dept. reported at 358 El that a scene and proceeded Brillo. I responded directly to headqu to the the necessary equipm arters where I pic ent and the crime ked up the crime scene. scene vehicle to pro cess I went in service at Upon arrival I noted 9:32 a.m. and arrived on the scene at that the house is 9:3 end of the street and is located on located at the extrem 3 a.m. the south side of e west the front of the hou the street with se facing north. story CBS type of The house is basica str lly a two is painted white and ucture having a white flat tile roof. metal closing gate there are walls app The trim s which are contro roximately 8' tall pad on the outside. lled with a electr wit h The re ar e whi onic touch of the entrance of te gargoyle figures on the gate as well the tops approximately 6" hig as black numerals The east most driv h indicating the addres e way is a large s numerics of 358. leading to a three flagstone type of car garage. drive way The dwelling has in two other gated ent addition to the main entrance to the rances which have garage them. These gates black floral lighte were metallic. Th d tops on into a circular fla e central gate whi gstone drive way was ch leads western most gate in the open positi was in the closed on. The locked on my approa position. The front ch was where there is a sma and I continued traveling to the wes ll double gate whi t gate closed". This ch gate was opened and has a sign, "Please keep a swimming pool. leads to a large pa To tio with way leading to a doc the west of the swimming pool is a k which then lead walk coastal waterway. s The dock was examin directly across to the intra ed and checked for any CONFIDENTIAL SONY_GM_M229&34 EFTA 00202590 EFTA01308919 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 7 Program: CMS301L signs of a boat tying 1-03-001498 (Continue up or the presence of d) left either debris suc anyone that may have h food containers, cig was found. It should arettes, cigars etc. be noted that the ext None 79 degrees and the hum erior temperature was idity was 63 percent. cabana at the southe Th ere is a small rn end of the pool whi equipment as well as ch had computer exercise equipment. touched or tampered None of this had bee with. n On the south side of the residence in the Epstein indicated tha southwest corner Mr. t he believed this intruder made entry was the area that the to the residence. The room and Florida typ room is a computer e room and has three windows present. The double sliding glass eastern most and wes identical in shape hav tern most are ing two glass panels three glass panels an . The central one ha d is the only one of s 14 flagstones leadin the three that has a g directly into the set of wood type of flooring room. The flooring and the western set is a found ajar, howeve of sliding doors was r the sandy area dire not indicate the pre ctly outside of the sen door did central window was fou ce of shoe prints or barefoot prints. nd ajar and still Th in the extended outwar had the lock mechanism e d position. The tw have been entered wer o windows believed to e processed and no found on the western latent fingerprints most, no fingerpri eastern most. There nts were found on the were fingerprint but could was one mark that was found that was no have been made fro t a rubber glove and thi m either a cloth or s was found on the a window. interior of the centra l Once inside the res idence, the person a veneer covered des went over to a des k which is black bag is approx k and there was a black bag underneat imately 2' long by h. The the southern side of 1' high and was pla the int eri or of ced on individual knelt dow the n and pulled the ca desk by the pedestal. The from a white envelo se open and remove pe. There were thi d cash bills left, still rteen one hundred in the envelope whe dollar one hundred dollar n I examined it. bills were removed The thirteen and Mr. Epstein an in the presence of d they wer Det, directly over to Mr. Epstein for sec e counted and turned desk, sides of the urity purposes. Th desk and bottom of e top of the latent fingerprints the and no latent finger desk was processed for on those areas. The prints of value were and processed chemic envelope will be transported to headqu found ally for latent fin art supplement to that gerprints. There wil ers effect that will fol l be a low. GREENE NARRATIVE Reported By: it 4 Entered By.: 10/09/03 On 10/06/03, at 110 10/09/03 0 hours, Det. 358 El Brillo and and I went to met with Mr. Epstei assistant n's personal footage of t e sus in regards to obt pect burglar. aining the video CONFIDENTIAL SONYGM_00329865 EFTA_0020259L EFTA01308920 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 8 Program: CMS301L 1-03-001498 (Continued) Det. 0426 MIS obtained a video of ending at 0430 hou mentioned video sh the footage starting rs. The before at ows a white male ins residence moving a duf ide the Epstein fle bag and opening drawer. A copy of th a desk is video footage was a compact disk and wa cap tured onto s placed into eviden property receipt. ce via a At 1400 hours, Det. Condominium, 1515 So and I went to the To ut wers Beach, where the sus agler Drive in West pect currently res Palm several video camera ides. I observed s a doorman at the mai on the outside of the building and n entrance on the building. south side of the At 1550 hours, I was Greg advised by Crime Sc that he had located ene Manager suspect Aleasi fro fingerprints for the m a Town of Palm Bea identification car ch d application. At 1630 hours, I cal led the Towers Con spoke with the manage dominium and r of the condomini verbally identified um who himself to me as Don Dement eve me his direct business num ald Dement. and his home phone ber number Dement told me that wi t e name Alessi but he was familiar recognize him. Dement he advised he wouldn told me that they 't video cameras and that they did record had several camera but the rec the surveillance ord night and he didn't ing system had broken on Sunday have anything on the tapes. Dement told me tha t the condo does hav doorman who stands e a midnight du anyone coming in the ty at the desk in the lobby and they come in, would building regardless of what door hav told me that the desk e to pass the doorman. Dement 0700 hours was Gre man for Sunday mor and he next worked ning, 2300 to Wednesday, on . Dement was not what Alessi rives familiar with or which parking spo advised that he wou t was his but he ld check and call morning. me back in the A Palm Beach County property search rev one Alessi owns the ealed that, property at , and has resided the re since 2001. Invest.Cont. GREENE NARRATIVE Reported By: S 5 , ELMER C. 10/15/03 CONFIDENTIAL SDNY_GMJX*29U6 EFTA_00202592 EFTA01308921 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 9 Program: CMS301L Entered By.: 1-03-001498 (Continued) On Monday, 10/15/03 at 2:00 p.m., Mr. Jef the police epar ment frey Epstein came and informed me that into with his former housem earlier today he me an Juan Alessi at t Beach. Epstein stated Gre en's Pharmacy in Pal th at he pre sented Alessi with m obtained off the vi a photograph deo surveillance sys admitted to breaking tem, whereby Alessi into the house and told Epstein that he taking the money. Al broke into the house essi Epstein usually ke to take a gun that eps behind his desk. gun so he took the mon He could not find ey. Alessi said he the problems and they no and his wife are hav lon ger live together. He wan ing because he was con ted the gun templating suicide. Epstein stated that Alessi has already stolen money and tha returned $2,000. of t he will be making the to pay off the rem arrangements with Ale aining funds. I ask ssi Alessi's current add ed Epstein if he kn ress or phone number ew of Alessi was going to and Epstein said that call him at 5:00 p.m make arrangements . today and he wou for Alessi to come ld be interviewed. Eps into the police sta tein stated he no tion to Alessi but is concer longer wants to pro ned over the fact secute he broke into the that the gun Alessi hou sai said he does not hav se to steal is still missing, yet Alessid e it. ATTN POLICE CLERKS : and arrangements hav As Alessi has returned $2,000. to Eps e been made for the tein the money, please return of the rest show a full recove of ry of the $2700. ca ********************* sh. ** *******NARRATIVE GREENE # 6 Reported By: Entered By.: 10/15/03 On Monday, 10/15/03 , Det. and / responded to 15 Flagler Drill, 15 South we met...Mrs. Ma stated she does not ry Alessi. Mrs. Ale provided us with a kno w he r husbands current ssi cell phone for him address and Alessi, Det. . While speaking made telephone con to Mrs. made arrangements to tact with Juan Ale mee t wit h him back ssi and Department. Accord ing to Mrs. Alessi, at the Palm Beach Police husband Juan P. the last time she sa Alessi, DOB According to Mrs. , was today, 10/13/03. w her Alessi, she was at on Okeechobee Blvd. Ross when she saw her hus Department Store located stated she received band drive by. Sh at which time she a telephone call fro e did not talk to him m him on her cell pho divorce attorne . per instructions by ne Mrs. Alessi stated he r her husband on prior to that she , in which she res last saw building, 1515 ou ponded to the apartm t Mrs. Alessi stated ag er Dri ve, at approximately 2:00 a. ent she contacted West m. via 911, and office Palm Beach Police r's responded. I Department Police Department contacted the West Pal whi m Officer Sean Philli ch queried their CAD system and confir Beach ps responded to tha med t address in refere nce to a CONFIDENTIAL SONY_GM_00329867 EFTA_00202593 EFTA01308922 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 10 Program: CMS301L 911 phone call. There 1-03-001498 (Continue is no report on file d) entry only that Juan and list said CAD P. Alessi was in the civil matter. They building reference to hav a This concludes my inv e no current information for Mr. Alessi. olvement in the matter . GREENE NARRATIVE # 7 ***** ********* Reported By: A.*********** Entered By.: 10/15/03 On 10/15/03 and I went to at empt to ocate sus , 171.11F iail n la pect uan essi. As we were getting into the ele vat contact with Alessi's or on the ground floor, we came in wife, Marie Alessi Marie why we were . I explained to there and she agreed to speak to us. Marie said she and her husband, Juan separated for approx Alessi, have been imately two months going through divorc an e proceedings. Mar d they are longer lives with ie said Juan no her at this addres order which states s and she has a court Juan is to have no Marie said on this contact with her. date, at approxima Juan drove by her as tely 1100 hours, Department Store loc she was walking out of the Ross ated on the southe Okeechobee Blvd. and ast corner of waved at her and tha Military Trail. Marie said Juan t was the extent of Marie said she does their contact. not know where Jua said he is driving n is living. She a white Caravan. with Juan's cell Marie supplied me phone number, advised Juan has bee . Marie n separation. I advise depressed ate y, due to their d Marie to be awar surroundings and be e of her on the lookout for comes in contact wit Juan and if she h him to call the immediately. Marie police also su lied me phone number, John Ale with her son's ssi, I called Juan Alessi come to the Palm Bea on his cell phone. Juan agreed to ch Police Station Juan arrived at the for an interview. in the interview roo pol ice department and m I placed him Juan his Miranda Rig in the Detective Bureau. I read which he stated he hts from a prepared rights card in understood and sig ned . I asked Juan what his connection was he lives at 358 El with Brillo. Juan said he Mr. Epstein, Epstein from Januar worked for Mr. y 1991 to until Sep the house manager. tember 2002, as Juan said he was ve Epstein's schedule ry familiar with and the lay out of Juan if he took mon the house. I asked ey and a gun from past weeks and Juan Epstein in the take money from Eps said he did not take the gun but di tein's house. Jua d approximately six n weeks ago he became explained very depressed CONFIDENTIAL SONYGM_00329888 EFTA_00202594 EFTA01308923 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 11 Program: CMS301L about his break up wit 1-03-001498 (Continued) h his wife along wit medical condition h a cancerous he was fighting. Jua became suicidal and n advised he decided to steal a gu Epstein in order to n from Mr. kill himself. Juan Epstein had a gun in said he knew Mr. his office because he Epstein put it there. helped Mr. revolver with a medium Juan described the gun as a silver did not know the exa barrel that was holste ct date, but he said red. Juan approximately six wee it was ks ago at about 05 Sunday morning, he dec 00 hours on a ided to enter Mr. house at 358 El Bri Epstein's llo gun. Juan said he dro Avenue, in an attempt to steal the ve his white Carava in the driveway of n and parked it the house. Juan sai house through an unl d he entered the ocked sliding glass near Epstein's off door located ice. Juan said he ent and attempted to loc ered the office ate the gun. Juan sai the office but could d he searched went into Epstein's not find the gun. Juan said he then briefcase and remove approximately $1900. d in one hundred dol white envelope. Jua lar bills from a n immediately left the said after taking the money he house. Juan said on Sunday mor approximately 0500 hou ning, 10/05/03, at rs, he decided to El Brillo in order to ret steal money once aga urn to 358 Epstein. Juan said in from he once again drov Caravan to the house e his white entered the house and par ked in the driveway. through the slidin Juan entered the office g glass door and . Juan said he ope and removed $5600. ned the briefcase in white envelope. Jua one hundred dollar bills from a n said he left thr glass door and drove ough the same wore a creme colore away. Juan said he believed he d short sleeve shirt, loafers, light colored pants, a and a baseball hat not wear gloves on . his hands. Juan sai Juan said he did money to pay for hi d s girlfriends immigr he needed the ation papers. I asked Juan if he was still suicidal. not and that he was Juan said he was seeing a psycholog basis. (this was ver ist on a weekly ified by Juan's so once again denied n, John Alessi) Jua taking a gun from n Juan said he had a Epstein's house. talk with Mr. Epstei and they agreed Juan n on 10/12/03, money that was taken. would pay Epstein back for all the I placed the Mirand a Rights card along tape of Juan's adm ission, into eviden with the VCR ce. ATTN POLICE CLERKS : Please add the fol names and their inf lowing ormation into the sys Alessi, W/F, DOB tem. Marie , West Pa m Beach, Florida 33407. Joh n CONFIDENTIAL SONY_GM_0(M2VWS EFTA_00202595 EFTA01308924 Date: 9/13/07 Time: 14:03:07 PALM BEACH POLICE DEP ARTMENT Page: Incident Report 12 Program: CMS301L Alessi, W/M, DOB 1-03-001498 (Continued) Alessie DOB unknown address, Juan st ne on ********************** ************** GREENE * If 8 Reported By: Entered By.: 11/12/03 • 11/12/03 on Officer Wei Alessi, the vehicle par ss advised me that he had located Jua ked in parking spa n Condominium. Office r Weiss further adv ce 85, at the Towers vehicle was a Ford ise Explorer, dark in col d that Alessi's U72UGL. or, bearing Florida tag On I was advised by Sgt. wit... and had reached an Trylch that Epstein had agreement to pay bac met taken and subject k the money Epstein did not wish I was also advised to prosecute at th that Det. is had obtained a full had interviewed Alessi time. confessiolli i ihe and denied taking the theft of the money but Glock hand gun. had In previous conver sations, Epstein was of the hand gun but not believed it had possib sure of the location books behind his des ly been between the k. The surveillance Alessi taking the vid eo does not show hand gun and Alessi denies taking the gun. On 10/15/03, at 14 00 hours, I faxed to Epstein asking the affidavit of prosec tha ution he does not wish to t he complete the document indicating prosec ute and fa x it that mailing the origin back to me along wit al back to me for h my case file. At 1500 hours, Det . removed the equipment from Eps tein s residence loc video surveillance ated at 358 El Bri llo. Several attempts to obtain the affidavit indicated that Epstei of prosecution with no response fro n did not wish to prosecute were met m his staff. It sho Epstein had person uld be noted that ally met with Capt. that time advised he no longer wished Elmer and at Alessi for the bur to pro". Juan glary and theft from his residence. ATTN POLICE CLERKS : Please show a fu Currency. Please do ll recovery of the not show the Glock U.S. Please show this ca hand gun as stolen se as **Except.Cle . of the suspect was ared** as the identi established, there ty to support an arrest was enough informati , on known and the victim the exact location of the offender declines to prosec is ute. * * * * * * * * * * • * * * * * END OF REPORT CONFIDENTIAL SDNY_GM_00329870 EFTA _0020259( EFTA01308925