EFTA00723522

IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY, 
FLORIDA 
S 
CASE NO: 
Plaintiff, 
50200SCA037319XXXXMB AB 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
I 
PLAINTIFF'S RESPONSE TO EPSTEIN'S 
MOTION FOR SANCTIONS AND TO IDENTIFY 
Plaintiff, M. files this Response to Epstein's Motion for Sanctions and to Identify. 
introduction 
Apparently Epstein and his counsel do not have a problem with press, they just have a 
problem with bad press. To put the quotes cited by defense in their motion in context, the court 
must also see some of the numerous quotes given by Epstein's defense team. 
"These women are liars. We've established that " 
"It was just a childish performance by the Palm Beach Police Department " 
- Any. Jack Goldberger, August 8, 2006, Palm Beach Post. (Ex. I). 
"There was never any victims." (sic) 
- Any. Jack Goldberger, July 23, 2009, Palm Beach Post. (Ex. 2). 
EFTA00723522

"...because the craziness of this police chief we have the charge of solicitation." 
- Atty. Gerald Lefcourti, July 27, 2006, New York Post (Ex. 3). 
"He never denied girls came to the house," 
Goldberger said. But when Epstein was given a 
polygraph test, "he passed on knowledge of age," 
the attorney said. 
- Atty. Jack Goldberger, July 29, 2006, Palm Beach Post (Ex. 4). 
"Defense attorney Jack Goldberger maintains that 
not only did Epstein pass a polygraph test showing 
he did not know the girls were minors, but their 
stories weren't credible." 
- Atty. Jack Goldberger, Aug. 5, 2006, Palm Beach Post (Ex. 5). 
"There was never any sex between Jeffrey Epstein 
and any underage women," his lead attorney, Jack 
Goldberger, said from Idaho where he was 
vacationing with his family. 
Epstein did have 
young women come to his house to give him 
massages, Goldberger said, "Mr. Epstein absolutely 
insisted anybody who came to his house be over the 
age of 18. How he verified that, 1 don't know. The 
question is did anything illegal occur. The law was 
not violated here." 
- Atty. Jack Goldberger, Aug. 8, 2006, Palm Beach Post (Ex. 1). 
The quotes above are just a few of the numerous quotes and information provided 
directly to the press and media by Epstein's litigation team over a two year period before 
Plaintiff S
 ever filed suit. In fact, as mentioned in the story, attorney Goldberger was so eager 
for media attention and publicity that the quotes in the first article cited were given while he was 
on vacation with his family in Idaho. 
(See Ex. I). After the instant civil suit was filed, 
Epstein's mob of attorneys and press agents continued to pepper the media with their "version" 
of the story. 
I Gerald Lefrourt isAvas one of Epstein's attorneys in New York. 
Page 2 of 15 
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"Are these comments not prejudicial to the administration of 
justice? Clearly, these comments, without supporting evidence, 
are nothing more than hyperbole and would never reach a jury. 
Nonetheless, [Mr. Goldberger and Mr. Lefcourt] chose to make the 
comments in an effort to prejudice....[the girls in this case]." 
"[Epstein's attorneys] forget their attorney oath which reads, in 
pertinent part: `I will abstain from all offensive personality and 
advance no fact prejudicial to the honor or reputation of a party or 
witness, unless required by the justice of the cause for which I am 
charged....[Mr. Epstein's attorneys] took this oath; however, 
[their] publicity seems more important than the very oath [they] 
swore to uphold." 
Above are direct quotes from Defendant's Motion for Sanctions filed in this case. (See 
Motion for Sanctions p. 4-5). Plaintiff has merely switched the names of the parties. Are these 
quotes not just as appropriate if applied to the comments made by Epstein's attorneys? When 
reading Epstein's current motion for sanctions, the often quoted phrases, "those in glass houses 
shouldn't throw stones" and "the pot calling the kettle black" come to mind. These quotes were 
merely the beginning of the publicity junket that has continued through today, with not only 
Epstein's criminal attorneys, but also his civil attorneys, such as Robert Critton. 
Epstein's team of attorneys utilized the press and media in a clear attempt to bias public 
opinion against his victims. Now that the victims and their attorneys are attempting to speak out, 
it would be a miscarriage of justice to sanction and silence the victims while the admitted 
criminal is allowed unfettered access to the press to pitch his cause.2
2 While Defendant's counsel takes issue with the branding of Mr. Epstein a "criminal", the facts and public record 
show that his has plead guilty to Ipirocuring a person under the age of 18 for prostitution; F.S. 796.03" and he is a 
registered Sex Offender as a result. (See Ex. 6). Furthermore, when comparing this plea to Goldberger's statement 
to the press in Ex. I this shows that Goldberger either permitted his client to plead guilty to a charge he did not 
believe his client committed, or he flat out lied to the press. Undersigned counsel is merely a civil litigator and does 
not handle criminal matters, but surely one of these two options is likely unethical. 
Page 3 of 15 
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Memorandum of Law 
Epstein identifies four separate issues as the foundation of his Motion: 
1. 
The Egg Shaped Penis deposition; 
2. 
The non-prosecution agreement, and quotes regarding same; 
3. 
Five various news articles; 
4. 
The Goldberger Affidavit. 
In addition, Defendant appears to throw in as an after-thought the argument that as a 
result of undersigned counsel's quotes, none of which directly discuss the facts of thee. case, 
somehow her anonymity should now be revoked. M. has never spoken to the press. Ns 
argument is illogical and should be denied. Each argument is addressed in turn. 
I. 
The "En Shaped Penis" deposition 
The deposition of Jeffrey Epstein was filed with the court and is a public record. "A 
lawyer may allow a newspaper reporter to inspect the lawyer's copy of a deposition taken in a 
civil suit of considerable public interest if the deposition is available for public inspection in the 
court clerk's office, if the reporter, not the lawyer, instigated the inquiry, and if the lawyer 
refrains from improper discussion of pending litigation." Fla. Ethics Opinion 65-43 (July 30, 
1965). This opinion was further amended subsequent to the United States Supreme Court 
opinion in Gentile v. State Bar of Nevada, 501 U.S. 1047 (1991) to allow attorneys to quote more 
liberally on legal proceedings which have public interest. 
In Gentile, the U.S. Supreme Court recognized that a vague regulation of public speech is 
impermissible and unconstitutional. A lawyer, like any other citizen, has a right to freedom of 
speech. The Gentile case involved a criminal defense attorney's comments to the press (not 
unlike those already cited in this case of Goldberger and Lefcourt). In Gentile the court required 
Page 4 of 15 
EFTA00723525

that any rule banning public speech of an attorney must comply with both the requirements of 
"imminent" and "substantial" detrimental effect on the proceeding. 
Florida's Rule 4-3.6 specifically states that "A lawyer shall not make an extrajudicial 
statement that a reasonable person would expect...will have a substantial likelihood of 
materially prejudicing and adjudicative proceeding due to its creation of an imminent and 
substantial detrimental effect on that proceeding." The release of the Egg Shaped Penis 
deposition clearly did not "materially prejudice" Epstein in any manner because the Palm Beach 
Police incident report and probable cause affidavit which included this description of Epstein's 
private part was a public record and already in the public domain, posted on various news 
websites since his arrest. See http:/lwvinv.thesmokinggun.com/archive/0726062eDsteinthiml 
(posted July 26, 2006). Additionally, there was no "imminent" court proceeding at the time the 
comments were made public. Mr. Epstein's case is not currently set for trial.3
In the comments to Rule 4-3.6 it states that "Wire public has the right to know about 
threats to its safety and measures aimed at assuring its security. It also has legitimate interest in 
the conduct of judicial proceedings, particularly in matters of general public concern." The 
Epstein matter is a great public concern as evidenced by the thousands of news stories 
throughout the world. All press inquires were unsolicited by undersigned counsel. During the 
litigation in this matter, and because of Epstein's notoriety, press agencies from throughout the 
world have been attempting to contact both undersigned counsel and counsel for Epstein. 
This deposition was filed and made public because Epstein walked out of his properly 
noticed deposition. Therefore, his deposition was made public record because of Epstein's own 
actions. Other than showing an individual's identity, there is absolutely no difference between a 
Page 5 of 15 
EFTA00723526

written transcript and a videotape for the purpose of public disclosure as it pertains to Epstein. 
Defendant cites absolutely no case law that can distinguish between a written transcript and a 
videotaped deposition.°
As a result of Defendant Epstein's actions, this court sanctioned him and ordered him to 
reappear for deposition. At hearing, this court properly pointed out that the questions asked by 
undersigned counsel, while personal in nature, were reasonably calculated to lead to the 
discovery of admissible evidence. In fact, this argument by Defense counsel is another example 
of Defendant and his counsel saying one thing, and doing another. As recent as December 3, 
2009, Epstein's counsel was reprimanded by the Federal Court and the United States Magistrate 
Judge Linnea It. Johnson for their deposition tactics and questioning. 
A review of the deposition transcript reveals numerous instances of 
Jane Doe 4 being subjected to repetitive questioning about 
exceedingly sensitive issues such as the emotionalir caused 1 
and Epstein's treatment of her. To re-phrase Plaintiffs' counsel's 
words, while it may be appropriate toilirlaintiff in a personal 
ilic iasestion 
abut whether
caused her 
when the essentially identical question is re-
phrased and asked over and over again, the questioning becomes 
badgering and harassing. Counsel for Defendant must be mindful 
that the depositions of the Plaintiffs in these cases covers the most 
intimate and private details of their lives and if not handled 
correctly may serve to needlessly re-victimize, embarrass and 
humiliate them. 
...counsel is expected to conduct himself in a responsible and 
professional manner befitting members of the Bar and balance the 
need for the information sought against the psychological trauma 
3 Alternatively, undersigned counsel points out that the comments made by Mr. Goldberger and his co-counsel in the 
press, as cited above, with the criminal trial pending and speedy trial issues, were clearly made to cause "imminent" 
detrimental effect on the criminal proceeding. 
Conversely, a Jane Doe or an anonymous Plaintiff is entirely different. A proper non-identified plaintiff is 
afforded her anonymity because of the illicit and illegal actions of Defendant and Plaintiff's age. Defendant Epstein 
is not afforded that protection because he is the perpetrator, his photo is on the Internet as a registered Sexual 
Offender, he is a known public figure and has been identified already in this proceeding. 
Page 6 of 15 
EFTA00723527

that could result from repetitive, humiliating questions regarding 
the sensitive issues at play in this case. 
Court Order Dec. 3, 2009 (Ex. 7). 
While Defendant now claims that undersigned counsel's conduct is somehow 
embarrassing or harassing, it is Epstein's attorneys who from the nexus of his criminal charges 
have taken a sledgehammer approach to discovery and publicity. The Defense tactic has been to 
bludgeon Epstein's numerous young accusers with negative press, heavy handed and intimate 
discovery questions and harassing deposition questioning. In no way was the release of an 
already publicly filed deposition improper or sanctionable. 
IL 
The Non-prosecution Agreement ("NPAn 
Defendant's argument about the non-prosecution agreement ("NPA") makes absolutely 
no legal sense. 
Similar fact evidence of other crimes, wrongs, or acts is 
admissible when relevant to prove a material fact in issue, 
including, but not limited to, proof of motive, opportunity, intent, 
preparation, plan, knowledge, identity or absence of mistake or 
accident, but it is inadmissible when the evidence is relevant solely 
to prove bad character or propensity.5
Fla. Stat. § 90.404(2)(a). 
In Florida, there is a general rule of admissibility of relevant similar fact evidence even though 
the evidence points to the commission of another crime. This evidentiary rule is commonly 
referred to as the Williams rule. See Williams v. &ate, 110 So. 2d 654, 659, 662 (Fla. 1959), 
cert. denied 361 U.S. 847 (1959). This evidence of collateral crimes or acts is admissible under 
s Fla. Stat. § 90.404(2Xb)1 thither states that "[fin a criminal case in which the defendant is charged with a crime 
involving child molestation, evidence of the defendant's commission of other crimes, wrongs, or acts of child 
molestation is admissible, and may be considered for its bearing on any matter to which it is relevant" While this is 
not directly applicable because the instant case is not a criminal action, it is persuasive since the policy behind this 
subsection is similar to a civil proceeding for the same, or similar, acts. 
Page 7 of I5 
EFTA00723528

section 90.404(2)(a) not because it is identical or even similar to the crime or act in issue, but 
because it is relevant to prove a material fact or issue in the instant case other than the 
defendant's propensity or bad character. Zack v. State, 753 So. 2d 9, 16 (Fla. 2000). This type 
of evidence is sometimes mistakenly referred to as "similar fact evidence," but the similarity of 
the facts involved in the collateral act or crime is not the test. Id. Here the court need not even 
address the issue of admissibility because the parties are merely engaged in discovery. Clearly, 
there is a good faith legal argument for the direct admission of similar fact evidence in this case 
to prove motive of Epstein to commit the sexual battery upon E., opportunity to commit this 
act, his intent, preparation, plan, knowledge ()f.'s age, identity of Epstein and the absence of 
mistake with respect to the girls' ages. All of these issues have been raised by the Defense. 
Regardless of admissibility, the discovery of the information in the N.P.A. is reasonably 
calculated to lead to the discovery of admissible evidence. 
As a result, through the proper legal court proceedings, undersigned counsel joined in a 
request to make public a document that did in fact lead to the discovery of relevant and pertinent 
information not only for the benefit of his client, but the general public and the system of justice. 
This NPA showed the previously secret deal cut by the U.S. Attorneys office with the Palm 
Beach State Attorney for the conviction of Defendant Epstein. It also identified by name co-
conspirators which were given immunity. 
The NPA is also relevant with respect to the bias of Epstein's co-conspirators who were 
given immunity. See Fla. Stat. § 90.608(2). "Any party, including the party calling the witness, 
may attack the credibility of a witness by:...(2) showing that the witness is biased." Id Is there 
a possibility that a named co-conspirator/witness may be bias in the civil proceeding, in favor of 
Epstein, because he negotiated for her immunity and freedom? See Morrison v. State, 818 So. 
Page 8 of 15 
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2d 432, 446-47 (FM. 2002)(disclosing a witness's self-interest is a proper purpose of attacking 
the witness's credibility). Without question, this is relevant cross examination material in the 
instant case. Until the release of this NPA, undersigned counsel had no way of knowing the 
terms of the deal or the co-conspirators provided immunity. 
Regardless, the Fourth District Court of Appeals granted undersigned counsel's petition 
and made the non-prosecution agreement public. See Epstein v. State, 16 So. 3d 315 (Fla. 4th
DCA 2009). This document also has direct implications on the allegations of Plaintiff's cause of 
action. It is now an Exhibit to Plaintiff's Amended Complaint which shows the broad sexual 
enterprise (i.e. R.I.C.O.) and co-conspirators Epstein utilized to abuse underage women at his 
home on Palm Beach and elsewhere. It strains reason for Defense counsel to claim that by 
utilizing the proper legal procedures, and winning at the appellate court level, Plaintiff counsel's 
lawful conduct is somehow sanctionable. 
M. 
Various News Articles 
Next, Defendant cites various news quotes from undersigned counsel relative to this 
proceeding. As previously stated infra, these quotes are within the constitutional mandates of 
both freedom of the press and free speech. See Gentile. Furthermore, it can hardly be said that 
Epstein's counsel has taken the tact of "no comment." 
Mr. Epstein is a man who has not, and does not, shy away from national and international 
publicity. 
He 
even 
has 
his 
own 
Wikipedia 
page 
on 
the 
iMemet. 
http://en.wikipedia.org/wiki/Jeffrev_epstein (See Ex. 8). This is a man who, long before the 
current litigation, had an international profile with friends such as former President Bill Clinton, 
Actors Keven Spacey, Chris Tucker, David Copperfield, and financial mogels like Les Wexner 
(owner of The Limited, Victoria's Secret, Abercrombie & Fitch and others). 
The facts 
Page 9 of 15 
EFTA00723530

surrounding his crimes were national and international news in print, television and on the 
interne. One need only Google "Jeffrey Epstein" to find over 36,000 stories on-line. (Ex. 9). 
Mr. Epstein's illicit actions are even contained within published novels. See Learner, Laurence, 
Madness Under The Royal Palms, Love and Death Behind the Gates of Palm Beach, Hyperion 
(2009) at p.175. The premise that, in the midst of this media deluge, four or five quotes by 
undersigned counsel somehow tainted Mr. Epstein's ability to receive a fair trial is laughable. 
Attached to this Response as Exhibit 1-5 & 10 are no less than nine (9) news stories containing 
quotes from Goldberger and other members of the Epstein defense team. 
In addition to this legal team, Mr. Epstein hired professional Hollywood publicists in an 
attempt to spin the media and attack his numerous underage accusers. (See Ex. 1). Mr. Epstein 
hired finned New York publicist Dan Klores — whose client list has included Paris Hilton and 
Jennifer Lopez — who was quoted as saying in an August 8, 2006, interview with the Palm Beach 
Post, that Mr. Epstein was ready "to get his story out." This crack legal team and publicity 
engine gave numerous interviews with the media in an attempt to smear the reputations of the 
minor victims of Mr. Epstein. 
In opposite to their present position, Epstein's counsel took a diametrically opposite 
ethical position, in a similar sexually charged and high publicity litigation. While the facts of 
that other case are irrelevant to the instant proceeding, the legal proposition is the same. In a 
case involving allegations of sexual harassment and battery with a high profile plaintiff attorney 
from Stuart, Epstein's current defense counsel freely gave interviews and information to the 
media, such as videotapes, to the press. (See Ex. 11). 
In this other litigation, Mr. Pike was quoted as saying Itjhis is nothing but a shakedown 
for money." (See Ex. II). The Critton firm then filed and made public the content of sexually 
Page 10 of 15 
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explicit DVD's showing the defendant's adult son having sex with one of the defendant's 
accusers. Pike was again quoted in the press saying "she claims she was assaulted by the father, 
yet a week later, she's making an amateur sex video with the son." (See Ex. 11). Mr. Critton is 
no stranger to the media either. In the past he has given numerous quotes to the Palm Beach Post 
about his cases, including one where he personally attacked an opposing litigant in the press by 
stating that "[he] has a pathological disorder." (See Ex. 12). Were Critton and Pike making 
comments in an effort to improperly prejudice the public and potential jury against their client's 
accusers, or were they merely exercising their First Amendment Rights to comment on evidence 
in the case? 
Critton has even given direct media interviews regarding his current client, Mr. Epstein. 
In an extremely ironic move, after filing his motion for sanctions against undersigned counsel, 
Critton gave an interview with the national publication AmLaw Daily.6 (See Ex. 13). In that 
detailed interview, Critton was discussing his recent filing on behalf of Epstein against disgraced 
attorney Scott Rothstein. The facts of Critton's complaint deal with the civil cases against 
Epstein which were handled by an attorney in Rothstein's office. Critton told the press "instead 
of a defendant having a legitimate discussion with a plaintiff to resolve a case, [Rothstein's] out 
there pitching millions in dollars from these other cases he claims to have" and further claims 
that Rothstein engaged in "abusive litigation tactics." Critton further told the press that he was 
seeking "at least $100,000 in damages and more than that if damages are trebled." 
6 A Palm Beach Post reporter also advised undersigned counsel that Critton's office dropped off a copy of the 
Complaint against Rothstein the same day it was filed with the court. Obviously, an attorney trying to avoid press 
would not voluntarily drop off a new complaint to the local newspaper. It is clear that Epstein's team were actively 
seeking out press on this issue. 
Page 11 of 15 
EFTA00723532

Critton appears to have no problem with quotes to the press when they favor his client's 
position. It is merely when the victims of his client speak out through their attorneys, when he 
takes issue. One cannot use the Rules as a shield and a sword. 
None of the statements made to the press by undersigned counsel were improper. 
Additionally, none of the statements cited by Defense were prejudicial to the administration of 
justice. Quotes cannot be read in a vacuum. Both Epstein and his victims have had equal 
representation of their version of events, and the allegations, in the media. To silence or punish 
just one party without the other, would effectively quash the constitutional freedom of speech by 
victims and their advocates from speaking out when attacked by their accusers representatives. 
IV. 
Goldberger Affidavit 
Of all the unfounded accusations outlined in Defendant's motion, it is the Goldberger 
affidavit that is the most disappointing. First, undersigned counsel denies the statements 
recounted by Goldberger in his affidavit. Second, and more importantly, it is a sad day when 
colleagues in a difficult and stressful profession cannot have a friendly, joking conversation apart 
from their usual advocacy and courtroom arguments. Frankly, the fact that Goldberger has filed 
this affidavit speaks more about him as an individual than any other filed document or quote to 
the press in this case. Undersigned counsel will show more discretion and not recount the 
similar out of context, and joking, comments Goldberger made in this same conversation about 
his family and his own client unless the court finds any merit to this argument. If so, then 
undersigned counsel will provide his own affidavit quoting everything said during the 
conversation misquoted by Goldberger. 
Regardless, this conversation had absolutely no bearing on the current litigation or either 
side's litigation strategy. For Goldberger to even try and use this friendly conversation as 
Page 12 of 15 
EFTA00723533

anything other than two colleagues discussing and joking about business is distressing to say the 
least. Unfortunately, Mr. Goldberger has shown himself to be an untrustworthy and unfriendly 
individual. That is just sad. 
V. 
Anonymity of Plaintiff, II 
As an apparent afterthought, Defendant somehow tries to leap to the conclusion that 
based on counsel's statements to the press, al should lose her anonymity. As cited above, 
Epstein's counsel has "solicited" untold amounts of publicity for himself. Conversely, not a 
single statement cited by Defense references the facts of M's specific case! 
The first case cited by Defense for this argument is Doe v. Frank, 951 F.2d 320 (11th Cir. 
1992). Ignoring for a moment that this is a Federal decision interpreting Federal procedure, 
Defendant's conclusions about this case and its applicability to the instant situation are awkward 
at best. Undersigned counsel can only assume that this argument is a cut and paste job from a 
similar motion filed by Defense counsel with the Federal Court in other Epstein litigation 
because it does not apply. Defense counsel properly cites the seven factors in Doe v. FYank 
which would afford a plaintiff anonymous status. See Defendant's Motion for Sanctions p. 9. 
Two of these seven factors are directly relevant to the instant case: "whether the plaintiff is 
required to disclose information of utmost intimacy" and "whether the interests of children are at 
stake." In a baffling display, Defense counsel then states in his motion that "Plaintiff does not 
fall under any of the factors." As recognized by the Federal Magistrate, this entire case is about 
intimate sexual conduct involving minors. 
Furthermore, S's 
identity has been known to Defense counsel since the inception of 
this litigation. As a result, all of the caselaw cited by Defense about "the purpose of discovery" 
Page 13 of 15 
EFTA00723534

is irrelevant. It 
and undersigned counsel have not done a single thing or taken any action to 
prevent the orderly discovery in this case. Further, Plaintiff does not disagree with any of the 
cases cited in paragraph 21 of Defendant's motion. The courts should be open to every person; 
but how is that relevant to revealing the identity of a sexual molestation victim? 
To identify a young girl who was molested by Defendant as a minor, serves absolutely no 
purpose other than a threat to embarrass and silence..'s counsel and any of Epstein's critics. 
Unfortunately, given the Epstein team's previous gorilla litigation tactics in both the civil and 
criminal proceeding, it is not surprising. Not a single case cited by Defendant stands for the 
proposition that comments by counsel regarding a defendant somehow vitiates a Plaintiff's 
entitlement to anonymity. As a result, this request should also be denied. 
Conclusion 
For the above mentioned reasons and argument, Defendant's entire motion for sanctions 
and to identify should be denied. 
7 Interesting to note, this is the same tactic that Epstein's counsel has taken repeatedly in the cases with other girls 
(i.e. to threaten to identify plaintiffs if they speak to the press), while alternatively Epstein's counsel apparently feel 
none of the similar constraints. 
Page 14 of 15 
EFTA00723535

CERTIFICATE OF SERVICE 
HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. 
Mail, postage prepaid, this 
day of ac
 o ,  aov,  to Jack A. Goldberger, Esq.= 
Bruce E. Reinhart, Esq., 
Robert D. Critton, Jr., Michael J. Pike,. 
LEOPOLD-.ICUV1N P.A. 
Esq. 
F orida Bar No.: 089737 
Page 15 of 15 
EFTA00723536

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EPSTEIN'S RELEASE UPSETS 'JANE DOES,'THEIR ATTORNEY 
SAYS 
BYLINE: 
SONJA »GE Ft. Pan Bosch Pa She W rlie-
DAM 44 23.2O09 
PUBUCATION: Pea Oka Pont. The fel) 
arum FINAL 
SECTION: LOCAL & BUSNE SS 
PAGE 113 
MEMO: Gel shwa up 
Mend Simi cesolde eta the .Wtey Epstein case.
PeimBoarPcst cOntrepeten 
Jere Ca No. 6 dd not witch Natin Wedrear/ ~Nog. CeNe »NOIONG ettanterate ateY Epstein sOON and on 
Beasonly. a he calked advise Pia Beech Corey Jii end •YPPed la a Cr an ad 
No, bock 13 Na Pan, Bead, 
Mtn!~ ton tun to mete It wigy. 
Yea, the hitayegrald It now. itnyelend *ea "now v.he Its dale his tkno - ree risito ID mantra d an 1 &awn eetego And 
Metes= ran annoy»,  Ce ceotan. Cheat» In weekly *CT h• goren Cane. 
Ba Jane Doe No 6 tee an. who ha Ned lawsuits Ivan font in the worked NL any Wo and autaCch aereehday. 
eva Vial he was read WC% a me, torch retailed Want:~ wilh =nay at poeet. 
A!"! 
a *nun MinAns hat INOn Eed ~IM O» bar may mare« on bone of yard wan who clam to nth been 
IJs «dimt ran they wins tons 
'Tea as has any tame. »a we warm to  hoc tied ~as 
skeins, Mr. Epstein end we We chance them: 
Eppoinh attorney: Jack 001dberpert. said 
Roane Catitegors mats online, the entnyrrcus Ms. Doe teed Nael: 'Ca an not sidles— wild add you renkat dikeen 
tinny sesoutled by n Oa' men!
Nos 22. oho set she c 
wham; In Nth add yea Feria esnuiCy Cased her She was Ws-ninon:0 OY nie °tau& 
money ard poter ho Sae& she sere • 
Nor ender no Ora by Jane Dec Nos. 2 honk 6. says Ada Horowitz, wto mastiff each en sescra 
llsno timed» and cares fled on bail ce war aged *time dehaibt Epteleint peal ce cede nierisaccs one a 
era 
yohil Bar 
Macy. tor Ilse yang women - some aim te hone been as Bred as 12. fantod to liow1Z -soy he tirdded pay orkn 
torn he reread lobo weal), to tell or whose eredltdIty cold be eetles into qJeistion And 'te Sae n &Need to Non Co,
It, sane cases 
rtitear sNa lis chests anew in LacensaChee end GOyd Palm tech led von dick taken to the ~mien on El Brillo Wey by 
task 
Epstein daadtin gay In Joss 20» to two letery dwpn. pleCtaina a ace br coca ttian and &alley FeC4thLien The dad he 
m000 to gel on Wrenn conc.», is sored. thOUCM ths: een le ome plop charsilen n Count 
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Then they kind he ~sot swain int thet time in jell. 
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scot. Epstein an handier/ rattly al Lorne weekends enne last OCkhor os part ci a solintotee 
program. /le sealt het erne, ~10 
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No. the man's aK 
"They at ney ashotel Some teal say wattle MC heb out on the street des now.' areas ad. 
Farad cells to E psi/Wie attorney We MI retuned. 
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EFTA00723540

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20,2e9 1112 AM 
MOGUL DODGES JAJLBAIT CHARGE 
New Yodt Post- New York, N.Y. 
Date: 
Jul 27.2005 
Start Page: 
014 
Section: 
Page rot 
Tae Word Cant $95 
DoourneM hat 
IT looks like New York ttlioneire financier Jeffrey 
Epstein got off easy when ho was hit with s charge of 
soliciting a preset& for a "napPysndirer in Peen 
Beach. 
Because It Palm Beach police had rear way, Epstein. 
53 - who eurnmdered last Sunday and IF out on 
53.000 ball- mighthave been whacked Witi tar more 
serious charges ol paying underage girls for sex 
But a sego randier/bond the witnesses in the case 
were notittedible and threw cattail but the single 
deur Meek:ging a hooker n his hoar/Sous Perm 
Beasts home. Epstein lawyers and Mends now say 
he's the hapless Vetim of a vendetta by Palm Beech 
Ponce Chief Manse Reiter, whom they oesenbe 06 a 
'Immegaln nut case? 
Acconcmg to the police investgation. a copyof which 
from 17 witnesses and flw alleged act ms 
20. a 
who described herself as like a Heice Reiss: vase she got 
naked lo give Epstein a massage. Mn brought him slack's ages 14-16 for messages and sent his home. S.ee 
said theywere paid $200 per session. 
Cops also allege that Epstein's personal assistant 
who basal been charged, set up the IFIFFOFIS and 
put trash sheets on the massage table and supplied massage oils. Police searched through EpslePfs garbage end 
retriesed sex toss and feminine hygiene products. 
Epstent Palm Beach lawyer. JacitGoldberger. bid Page Six the the Florida state attorney concluded the caps had 
lookedatevidence from ii terie-S kited penspec5n.' He sated that Epstein had passed an ostensive lee-deteetor test 
In which he was grilled aboutunderage pins. 
Epstein New York lawyer. Gerald LOW" sec, The prosecutor didn't want to bring anycharges in ttvs case. but 
because tot the vainest Of this paws chief.** haw the charge of solicitaton? 
How to make e lectricitY 
A shocidng new horneowner's kit the electric co's 
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What concerns you the most about today's health 
insurance system? 
ItorAten commetonde Nay 
A spok•SWOman tot Reiter said ,strer think our knesfigolion speaks to 
leuvoeurea with Dterat !Cri of the merlin Ove4f. FWaer ftPtOduel:011Ce digabubon inn/need without PerentiOn. 
Abstract (Document Summary) 
Cops also allege that petty EpsteinTs personal assistant-, 
who hasn't been charged, setup the 
liaisons and put trash sheets on tne massage table end supplied massage Oh. Police searched Ihroof$IBOstelnt 
garbage and retieved sex toss and fern hese hygiene products. 
Epstein's Patin Beech lawyer, Jadc Goldberger. told Page Six thet the Florida slats *bonny concluded he cops had 
looked at midence horn eckne-s tried pers pease.' He added that Epstein had passed en etans 
lie-detector test 
in which he was grilled about underage pins. 
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