EFTA00178967

and I had lunch together on July 25, 2007, and Roy Black's name came up 
during our conversation. At that time, I relayed to Special Agent 
what Mr. 
Kleiman had told me. 
I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing 
is true and correct to the best of my knowledge and belief. 
Executed this  1
n day of July, 2007. 
Detective 
Palm Beach County Sheriffs Office 
Page 3 of 3 
EFTA00179187

(Rev. 061200.()Scakd Document Tracking Fon, 
UNITED STATES DISTRICT COURT 
Southern District of Florida 
Number: FGJ 07-103 (WPB) 
In Re 
Grand Jury Subpoenas Duces Tecum 
Numbers OLY-63 and OLY-64 
EX PARTE DECLARATION NI IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH 
SEALED DOCUMENT TRACKING FORM 
Party Filing Matter Under Seal 
, Name:'—
 U.S. Attorney's OMee 
On behalf of (select one): 
Address: 500 S. Australian Ave, Suite 400, West Palm Beach, FL 33401 
Telephone: a 
Plaintiff 
0 Defendant 
Date sealed document filed: 7/3112007 
If sealed pursuant to statute, cite statute: Fed. R. Grim. P. 6(e) (Grand Jury Maisnal) 
If sealed pursuant to previously entered protective order, date of order and docket entry number:  
The matter should remain sealed until: 
K Conclusion of Trial 
O Arrest of First Defendant 
• 
Case Closing 
O Conclusion of Direct Appeal 
O Other:  
E3 Permanently. Specify the authorizing law, rule, court order: 
The moving party requests that when the sealing period expires, the filed matter should be (select one): 
O 
Unsealed and placed in the public portion of the court file 
O Destroyed 
El Returned to the patty or counsel for the party, as identified above 
Attorney for: !Nonni United Sign of America 
EFTA00179188

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
IN RE GRAND JURY SUBPOENAS 
DUCES TECUM NUMBERS 
OLY-63 and OLY-64 
FGJ 07-103(WPB) 
EX PARTE DECLARATION NUMBER ONE 
IN SUPPORT OF UNITED STATES' RESPONSE 
TO MOTION TO QUASH SUBPOENAS 
FILED UNDER SEAL 
EFTA00179189

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
IN RE GRAND JURY SUBPOENAS 
DUCES TECUM NUMBERS 
OLY-63 and OLY-64 
/ 
FGJ 07-103(WPB) 
UNDER SEAL 
EX PARTE DECLARATION NUMBER ONE 
IN SUPPORT OF UNITED STATES' RESPONSE 
TO MOTION TO QUASH SUBPOENAS 
I, 
state that the following is true and correct to the best of my 
information and belief: 
1. 
I am currently employed as a Special Agent with the Federal Bureau of 
Investigation ("FBI") and have been so employed for the past ten years. I am assigned to the 
Miami Division, Palm Beach County Resident Agency, and for the past three years, I have 
been assigned to investigate mostly child exploitation cases. 
2. 
In the Spring of 2006, Detective  
kith the Town of Palm Beach 
Police Department ("PBPD") contacted me about the investigation of Jeffrey Epstein's 
solicitation of minors to engage in prostitution and his lewd and lascivious conduct with 
minors. The FBI opened a case file in July 2006, and I am the case agent assigned to the 
investigation. 
3. 
At around the same time that the FBI opened its investigation, the U.S. 
Attorney's Office began a grand jury investigation. I am one of the agents on the Federal 
Page 1 of 9 
) 
EFTA00179190

Rule of Criminal Procedure 6(e) list, that is, someone who is authorized to have access to the 
facts of the investigation and the materials related thereto. 
4. 
As part of the grand jury investigation, a subpoena was issued for all of the 
physical evidence obtained by PBPD during the course of its investigation, including the 
evidence seized when PBPD executed the search warrant at Jeffrey Epstein's home in 
October 2005. 
5. 
From my review of the photographs from the execution of the search warrant 
and my conversations with Detective 
, I believe that certain items were 
purposely removed from Mr. Epstein's home in anticipation of an execution of a search 
warrant. This includes the three computers which are the subject of grand jury subpoena 
numbers OLY-63 and OLY-64. 
6. 
I believe that the computers will be helpful to the grand jury investigation in 
several ways. First, one of the possible crimes that Mr. Epstein has committed is the travel 
in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor, in 
violation of Title 18, United States Code, Section 2423(b). Another possible offense is the 
use of a facility of interstate commerce to persuade, induce, or entice a minor to engage in 
prostitution or other illicit sexual conduct, in violation of Title 18, United States Code, 
Section 2422(b). A telephone is a facility of interstate commerce, so evidence of the use of 
the telephones to arrange appointments for sexual activity is evidence of a violation of 
Section 2422(b). 
Page 2 of 9 
EFTA00179191

7. 
From items recovered during the PBPD investigation and the FBI's own 
investigation, I know that some member or members of Mr. Epstein's staff documented daily 
messages for Mr. Epstein, to include telephonic and electronic mail messages, utilizing the 
URL (Uniform Resource Locator) address, http://domsrv0l/foxhaven/wc.dll?Gmax—Msg-
Display. Computer printouts displaying this information were recovered by PBPD from the 
trash located at Mr. Epstein's residence, 358 El Brillo Way, Palm Beach, Florida. One of the 
electronic message logs on the computer printouts documented a message left for Mr. Epstein 
on April 11, 2005 at 4:29pm by 
la, 
Mr. Epstein's assistant, regarding the 
availability of an identified underage female to "work". Review of cellular telephone records 
indicated telephonic contact between telephones utilized by.. 
and the same identified 
underage female on April 11, 2005 at 4:24pm. The electronic message logs recovered also 
displayed other types of appointments and travel plans. 
8. 
Therefore, a review of Mr. Epstein's computers may provide additional 
electronically stored message logs which could be further evidence of Mr. Epstein's intent 
to travel to engage in sexual activity with teenagers he recruited from five Palm Beach 
County high schools. Based upon the investigation, I believe that someone other than Mr. 
Epstein prepared the computerized calendar and telephone messages. Thus, Mr. Epstein 
would not be required to authenticate any such documents recovered from the computer. 
9. 
The second way that the computers will assist the grand jury is the possibility 
that photographs of the crime victims and/or child pornography may appear. I know from 
Page 3 of 9 
EFTA00179192

Detective 
that, at one time, Mr. Epstein had a security system that automatically 
downloaded images from surveillance cameras onto a computer. Detective 
learned 
about that in an unrelated theft investigation in October 2003. In October 2005, during the 
execution of the state search warrant at Mr. Epstein's residence, PBPD investigators observed 
pre-existing surveillance cameras in place but disconnected from recording equipment. The 
disconnected cables were located in an area where computer equipment appeared to have 
been removed. The FBI investigation has determined that Mr. Epstein was actively involved 
in lewd and lascivious conduct with minor females as early as March 2004. To the extent 
that Mr. Epstein tries to deny that any or all of the victims ever visited his home, video 
footage of them at the house would rebut such a claim. 
10. 
During the interview of another identified crime victim, it was revealed that 
Mr. Epstein had taken a picture of her standing near a marble bathtub. She was naked and 
looking over her shoulder. Mr. Epstein took that photograph at his Palm Beach residence in 
what the identified crime victim described as a bathroom in Mr. Epstein's master suite. 
11. 
Also, during the FBI's investigation, I interviewed a young woman, "M," who 
had known Mr. Epstein several years ago, when she was in her late teens/early twenties. The 
woman was a struggling artist in New York who was specializing in painting nude portraits. 
Prior to preparing a portrait, "M" would take several photographic studies. Mr. Epstein was 
very interested in her work and her photographs, and also expressed an interest in the artist's 
younger sister, "A," who was 16 years' old at the time. 
Page 4 of 9 
EFTA00179193

12. 
Mr. Epstein and his associate, Ghislaine Maxwell, made arrangements and paid 
for "M" to fly home to Arizona for the primary purpose of taking artistic photographs of her 
family members in the nude. This included the artist's younger siblings, that is, two sisters 
("A" and a younger sister, age 9 or 10), and her two brothers. Due to the sensitive nature 
of the photographs, "M" created a photo log to document each image and the order in which 
it was taken. Later, "M" learned that seven photographs, two of "A" and five of the 9- or 10-
year-old, were missing. "M," who was very upset, contacted Mr. Epstein's office and asked 
for one of Mr. Epstein's assistants to look for the missing photographs. "M" also confronted 
Mr. Epstein and Ms. Maxwell about the missing photographs, which they claimed they did 
not possess. A few weeks later "M" received a telephone call from an unidentified caller 
who stated that the missing photographs were in Mr. Epstein's briefcase. The missing 
photographs have never been recovered and "M" believes that Mr. Epstein is in possession 
of them 
13. 
Mr. Epstein and Ms. Maxwell also made arrangements and paid for "A," "M"'s 
younger sister, age 16, to travel to one of his homes, located in New Mexico. One morning 
during that visit, Mr. Epstein got into bed with "A." Mr. Epstein told "A" that he felt like 
"cuddling." "A" described Mr. Epstein's actions as "spooning" and constantly hugging her. 
14. 
During the FBI interview with "A," she became visibly disturbed when 
recalling an incident with Mr. Epsein at his ranch in New Mexico. "A" stated that one 
evening Mr. Epstein had come into her bedroom and sat on the bed. Mr. Epstein stroked her 
Page 5 of 9 
EFTA00179194

hair and told her she was beautiful. "A" was unable to recall the remainder of the events for 
that evening. 
15. 
I have interviewed "M" and "A" about their experiences with Mr. Epstein. 
Both "M" and "A" are reluctant to divulge their experiences publicly. "M" has also 
expressed her concern about speaking publicly against Mr. Epstein for fear of reprisals 
against her or her family. 
16. 
Further evidence of Mr. Epstein's potential interest in underage females and 
child pornography was the open display of three photographs in his Palm Beach residence 
which were seized during the execution of the state search warrant. Attached hereto as 
Exhibit A is a photograph which depicts a prepubescent female toddler exposing her 
genitalia. Attached hereto as Exhibit B is a photograph which depicts a prepubescent female 
pulling down her underwear exposing her left buttock. Attached hereto as Exhibit C is a 
photograph which depicts Mr. Epstein attempting to bite the clothed buttocks of a 
prepubescent female (the prepubescent female's skirt is raised exposing her underwear). 
17. 
Based upon this information, I believe a review of Mr. Epstein's computers 
may reveal images depicting crime victims and/or child pornography. In light of "M"' s fear 
of testifying against Mr. Epstein, the computer's contents may be the only admissible 
evidence of Mr. Epstein's interest in child pornography at trial (assuming that such evidence 
is discovered). 
18. 
The information related to the computers also would be helpful to the grand 
Page 6 of 9 
EFTA00179195

jury in trying to determine if any evidence exists that may indicate Mr. Epstein's involvement 
in the obstruction of justice through the tampering with or destruction of evidence. 
Additionally, evidence related to the computers may indicate Mr. Epstein's knowledge of 
guilt. Case law states that attempts to flee or hide or destroy evidence can be considered as 
evidence of a guilty mind. 
19. 
Other crimes that the grand jury is investigating, which were not the subject 
of the state investigation, are promotion money laundering, in violation of 18 U.S.C. §§ 1956 
and 1957, and aiding and abetting unlawful money transmitting by a financial institution, in 
violation of 18 U.S.C. § 1960. Both of these offenses involve the transmission of funds 
between different banking accounts owned by Mr. Epstein in order to promote prostitution. 
Through the grand jury investigation, documents from bank accounts have been obtained that 
show transfers of large sums of money (as much as $250,000 on a single day) from one 
personal Epstein account into an account purportedly owned by JEGE, Inc. (an entity created 
for the sole purpose of holding Epstein's personal Boeing 727 aircraft), and then to another 
personal Epstein account. It is believed that the computers may hold information related to 
those bank accounts and bank transactions. 
20. 
With respect to the computers that are the subject of the pending grand jury 
subpoenas, through the grand jury investigation, I was asked to interview Janusz Banasiak, 
the property manager for Jeffrey Epstein's Palm Beach home. Banasiak worked in that 
position during the time of the execution of the search warrant. I asked Banasiak whether 
Page 7 of 9 
EFTA00179196

he had removed the computers from the Epstein household. He stated that he had not, and 
that 'ME' 
and a private investigator, "Paul," had come to the house and taken the 
computers away. I know from the investigation that `IIIM" is 
, also known 
as 
who sometimes worked as a personal assistant to Jeffrey Epstein. Ms. 
is considered a target of the investigation, but neither Ms. 
nor Mr. Epstein is 
aware of that classification at this time. I know from the investigation that "Paul" is Paul 
Lavery, a private investigator who has had contact with several identified victims. 
21. 
A grand jury subpoena was served on Mr. Lavery at his residence in Hialeah, 
Florida. Mr. Lavery hired an attorney and initially refused to respond to the subpoena. 
Eventually, based upon conversations between Assistant United States Attorney 
and counsel for Mr. Lavery, a telephonic interview was conducted of Mr. Lavery. 
During that interview, Mr. Lavery stated that he had traveled to Jeffrey Epstein's home in the 
fall of 2005 and that a woman (whom he believed was MI) 
had given him the computer 
equipment, already in boxes. Mr. Lavery stated that he had the computers for a few days, 
probably over a weekend, before he delivered the computers to William Riley. Mr. Lavery 
stated that he did not tamper with the computers while they were in his possession. 
22. 
Based upon the interview of Paul Lavery, grand jury subpoenas were prepared 
for William Riley and the Custodian of Records of his firm, Riley Kiraly. Riley Kiraly is an 
independent private investigation firm, with its own offices in Miami, Florida. Attached 
hereto as Exhibit D are copies of printouts from the Riley Kiraly website, explaining the 
Page 8 of 9 
EFTA00179197

services offered. Neither Mr. Riley nor Riley Kiraly works exclusively for Roy Black or any 
other lawyer or law firm. 
23. 
The grand jury subpoenas were served via acceptance of fax by William Riley. 
He did not indicate whether he still had custody of the subpoenaed computers. Based upon 
the foregoing facts and the additional facts set forth in the Declaration of Detective Patrick 
L. Paige, Palm Beach County Sheriff's Office, I believe that Mr. Riley either currently has 
the computers in his possession or knows who has them. At the very least, Mr. Riley can 
relay to the grand jury his actions concerning the computers that were removed from Mr. 
Epstein's residence. 
I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing 
is true and correct to the best of my knowledge and belief. 
Executed this  3 4h day of July, 2007. 
Special Agent 
Federal Bureau of Investigation 
Page 9 of 9 
EFTA00179198

EFTA00179199

GOVERNMENT 
EXHIBIT 
C 
EFTA00179200

GOVERNMENT 
EXHIBIT 
B 
EFTA00179201

Contact Us 
Page 1 of 1 
HOME I 
COMPANY INFO I 
CASE MANAGERS I 
SERVICES I LINKS I NEWS I CONTACT US 
Riley Kiraly 
..Navigate our Site 
Las 
News 
F Al. O. 
Contact Us 
News Box 
r.'7 nflia 
Contact Us 
Contact us by e-mail, or phone 24 hours 
E-Mail 
Phone 
Fax 
Web Site 
www.rileykiraly.com 
A License 
0001308 
Address 
Commercial Center of Miami 
6135 N.W. 167 Street E-26 
Miami, FL 33015 
William Riley 
Stephen Kiraly 
Email of Principals 
GOVERNMENT 
D 
EXH
http://www.rileykiraly.conn/contact_us.htm 
7/30/2007 
EFTA00179202

Company Info 
Page 1 of 2 
HOME I COMPANY INFO I INVESTIGATORS I SERVICES I LINKS I NEWS I CONTACT US 
..Navigate our Site 
Ir ,f 
4-....A.fy:t 
News Box 
?mt."' 11104 
History 
Since 1979, Riley Kiraly has provided investigative and case preparation 
assistance to attorneys and corporate management in the United States, 
Europe, and Central and South Americas. 
The firm has an active local, national and international investigative practice, 
and serves clientele that includes multi-national banks, corporations, law 
firms and major insurance underwriters. A bilingual staff of fifteen (15) 
specialists bring many years of experience and expertise from various 
disciplines. 
Riley Kiraly has earned a reputation for relentless attention to detail, and is 
recognized as one of the leading investigative firms in the United States. 
Riley, Kiraly's commitment to excellence is reflected in every aspect of the 
firm's operation, from its experienced and qualified support staff to its state-
of-the-art communication and production equipment. All resources are 
utilized to deliver the utmost professional service. 
The Principals 
Riley Kiraly is owned by William H. Riley and Stephen N. Kiraly. 
William H. Riley began his professional investigative experience in 1966 
when he joined the City of Miami Police Department. He spent eight years 
working undercover investigating drug smuggling and money laundering 
cases throughout the United States, Central and South America. In 1968 he 
was named Officer of the Year and awarded a Gold Medal for Valor, the 
department's highest honor, for his undercover work as a Special Investigator 
for three Dade County Grand Juries, in Mexico and South America. In 1976 
Mr. Riley became the Chief Investigator for the Organized Crime / Public 
Corruption Prosecution Unit of the Dade County State's Attorney's Office. 
Here he handled major white-collar crime, complex financial, organized 
medical fraud and corruption investigations resulting in numerous arrests and 
convictions. 
In 1979, Mr. Riley left public service and entered the private sector and 
started his own investigative firm handling investigations dealing with internal 
theft, bankruptcy fraud, securities fraud and white-collar crimes. Mr. Riley 
also specializes in locating and evaluating assets and records on a worldwide 
basis, particularly in complex financial investigations. On Augusts 9, 1999, 
he was the featured front-page story in USA Today. Email William Riley 
Stephen N. Kiraly has over thirty-four years of investigative experience in 
both the public and private sectors. Mr. Kiraly's background Includes 
extensive experience assisting in complex civil and criminal investigations 
http://vvww.rileykiraly.com/company_info.Man 
7/30/2007 
EFTA00179203

Company Info 
Page 2 of 2 
around the world. 
Mr. Kiraly works with numerous law firms and corporations within the United 
States and internationally on high profile, complicated litigation matters 
involving fraud, internal theft, asset location, and recovery as well as a broad 
spectrum of additional issues arising from criminal and civil matters. 
Mr. Kiraly began his professional career in 1969 when he joined the Miami 
Police Department. He spent seven years working narcotic and drug 
smuggling cases and was assigned to the United States Department of Justice 
Task Force on Narcotics. He has extensive investigative experience as a 
Miami Police Department Homicide Detective. 
Mr. Kiraly has been featured in print and electronic media including the 
August 9, 1999 front page story on investigators in U.S. Today, on CNN as an 
investigative expert with Gretta Van Sustern, as well as other national and 
local television coverage. Email Stephen Kiraly 
IMp://www.rileykiraly.com/company_info.htm 
7/30/2007 
EFTA00179204

Services 
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We now have bomb and 
drug dogs available. 
Services 
Investigations 
The central concentration of our Investigative services is on very complex international 
crime and asset location, high impact litigation preparation, and specialized critical amid( 
management for corporations. 
Corporations, law firms and financial institutions look with confidence to Riley Kiraly for 
consultation and direction in the most sensitive matters affecting business risk. Securitl 
and systems design is offered to corporate clientele. Personal Protection and safety trail 
is provided to Individuals. 
Financial - We are capable of locating and seizing assets worldwide. We have expert 
experience with asset location and Mareva actions. We are often retained by financial 
institutions, governments and law firms to provide tactical investigative support in Antor 
Piller actions. 
Surveillance Operations - We regularly monitor and video record the activities of thos 
under investigation. Surveillance can be accomplished at any time in almost any state c 
country. Invaluable evidence and facts are gathered for litigation, asset location, custoc 
issues, internal theft or any tome you simply need to know. 
Background Investigations - Detailed background Investigations of witnesses, litigant 
parties in M&A matters, employees or prospective partners or employees. 
Locates - Whether a person is a witness, defendant, debtor, suspect, or fugitive, we ha.
the experience and expertise to locate them. 
Labor Related Investigations - We routinely assist management in matters involving 
internal theft, allegations of misconduct, sexual harassment, workplaCe violence, misuse 
company computer systems and critical incident handling. 
http://www.rileykiraly.con-ilservices.htin 
7/30/2007 
EFTA00179205

Services 
Page 2 of 2 
Physical Security and Risk Analysis - Our detailed security surveys and penetration 
studies allow management to control risk, evaluate existing security procedures. We 
provide expert, unbiased reports on internal or contract security operations, budgeting 2 
staffing. 
Electronic Countermeasures Survey - This service is provided to corporations who 
suspect their phones or business has been Illegally monitored in violation of law. 
Countermeasure services are also available to those in domestic litigation who feel the o 
party tapped their phones. 
Personal and Executive Protection - Michael Soppelsa supervises other highly trainer 
professionals in providing protection for our clients who require a secure environment at 
home or while traveling. We train our clients and their employees in personal security 
measures. Individual firearms training is also available. 
Air Travel Security - We develop and Implement airport and air travel security and dru 
interdiction programs for airlines and corporations flying to and from the United States a 
South and Central America. 
http://www.rileykiraly.com/services.htm 
7/30/2007 
EFTA00179206