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SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION-FIRST DEPARTMENT ··-····-·············-·-····-·····-··-··-············-··-···· X THE PEOPLE OF THE STATE OF NEW YORK, App. Div. No. 6081 - against - JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. On Appeal from New York Supreme Court, New York County, Index No. 30129/10 (Pickholz, J.) X NOTICE OF MOTION BY NYP HOLDINGS, INC. TO UNSEAL APPELLATE BRIEFS PLEASE TAKE NOTICE that, upon the accompanying affirmation of John M. Browning sworn to on January 11, 2019, together with the exhibits annexed thereto, the accompanying memorandum of law and all pleadings and proceedings heretofore had herein, non-party movant NYP Holdings, Inc., by its undersigned counsel, will move this Court at a term thereof to be held at the Appellate Division Courthouse located at 27 Madison Avenue, New York, New York 10010, on January 21, 2019, at 10:00 a.m., or as soon thereafter as counsel may be heard, for an order unsealing the briefs in the above-captioned appeal. PLEASE TAKE FURTHER NOTICE that answering papers, if any, shall be served upon the undersigned on or before the last date permitted by CPLR 2214. 4848-4442-5859v.l 3930033-000039 Dated: New Yori,, New York January 11, 2019 Respectfully submitted, DAVIS WRIGHT TREMAINE LLP By: __ Robert D. Balin John M. Browning -yv_/�ffj- 1251 Avenue of the Americas, 21st Floor New York, NY 10020-1104 Telephone: (212) 489-8230 Facsimile: (212) 489-8340 Email: robbalin@dwt.com johnbrowning@dwt.com Attorneys for Non-Party Movant NYP Holdings, Inc. 4848-4442-5859v.l 3930033-000039 2 SUPREME COURT, APPELLATE DIVISION FIRST DEPARTMENT ··-· •••• -----. ----------- - ·-. ·--- • ------. -· .. --- ---. -- . -- . ---•• -•• -. -•. X THE PEOPLE OF THE STATE OF NEW YORK, Respondent, - against JEFFREY E. EPSTEIN, Defendant-Appellant. X App. Div. No. 6081 On Appeal from New York Supreme Court, New York County, Index No. 30129/10 (Pickholz, J.) AFFIDAVIT OF SERVICE STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) JOHN BROWNING, being duly sworn, states, I am not a party to the action, am over 18 years of age and reside in Kings County, New York. On January 14, 2018, I served a true and correct copy of the annexed by mail in the custody of Federal Express directed to the following: Martin Weinberg 20 Park Place, Suite 1000 Boston, MA 02116 Karen Friedman Agnifilo Assistant District Attorney - New York County One Hogan Place New York, New York 10013 David Aronberg State Attorney 15 th Judicial Circuit- Palm Beach County Florida 401 North Dixie Highway West Palm Beach, FL 33401 Dexter Lee Assistant U.S. Attorney Southern District of Florida 99 N.E. 4th Street Miami, FL 33132 Dated: New York, New York 4848-4442-5859v. l 3930033-000039 3 January 11, 2019 Sworn to before me this 11th day of January, 2019 ( . ... . LORETTA E. PEARV NoWY Public, State of New Yo$ No. 24-4931817 Com�f��:S�r!'f ��ty, at)Jd . ·• -· ---... . . . 4848-4442-5859v.l 3930033-000039 4 SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION -FIRST DEPARTMENT ------------------------- - -------- - -------------- --------- --- X THE PEOPLE OF THE STATE OF NEW YORK, App. Div. No. 6081 - against JEFFREY E. EPSTEIN, Respondent, Defendant-Appellant. AFFIRMATION OF JOHN M. BROWNING IN SUPPORT OF MOTION TO UNSEAL On Appeal from New York Supreme Court, New York County, Index No. 30129/10 (Pickholz, J.) John M. Browning, an attorney duly admitted to practice before the Courts of the State of New York, affirms the following under penalties of perjury: 1. I am an associate of Davis Wright Tremaine LLP, attorneys for non-party movant NYP Holdings, Inc., publisher of the New York Post (the "Post") and I submit this affirmation in support of the Post's motion to unseal the briefs filed by the parties in the above-captioned appeal. 2. The grounds for unsealing the appeal briefs in this action are set forth in the accompanying memorandum of law. I submit this affirmation to annex relevant documents and to state facts that are relevant to this motion, of which I have personal knowledge. 3. Annexed hereto as Exhibit A is a true and correct copy of an article written by Julie K. Brown and published by the Miami Herald on November 28, 2018, entitled "Cops worked to put serial sex abuser in prison. Prosecutors worked to cut him a break." 4. Annexed hereto as Exhibit B is a true and correct copy of an article written by Rebecca Rosenberg and Danika Fears, which was published by the Post on January 7, 2015, entitled "DA's office 'went easy' on sex offender Epstein." 4840-5788-8644v. I 3930033-000039 5. Annexed hereto as Exhibit C is a true and correct copy of an article written by Rebecca Rosenberg, Larry Celona, Susan Edelman and Isabel Vincent, which was published by the Post on December 1, 2018, entitled "Manhattan DA sided with pedophile billionaire after botching investigation." 6. On or about December 4, 2018, Post reporter Susan Edelman contacted Danny Frost, Director of Communications for Manhattan District Attorney Cyrus Vance Jr., and requested copies of the briefs filed by the District Attorney's office in the above-captioned appeal. Ms. Edelman stated that names of victims could be redacted before the briefs were disclosed. 7. Mr. Frost responded that he could not provide Ms. Edelman with copies of the briefs because they were filed under seal pursuant to N.Y. Civil Rights Law 50-b and that the District Attorney's office could only release the briefs, even with victims' names redacted, if this Court ordered the briefs to be unsealed. 8. Mr. Frost further indicated by email that "[i]f the Post petitions the court, and the court asks the People for our position, we will not oppose the petition for a redacted brief' (emphasis in original). A true and correct copy of that email correspondence is annexed hereto as Exhibit D. 9. On or about December 18, 2018, I contacted Jay Lefkowitz, who represented appellant Jeffi-ey Epstein in the above-captioned appeal. Mr. Lefkowitz told me that he no longer represents Mr. Epstein and referred me to Martin Weinberg, who currently acts as counsel for Mr. Epstein. I 0. On or about December 20, 2018, I spoke with Mr. Weinberg and explained the nature of the Post's motion to unseal the redacted briefs and the position taken by the Manhattan 4840-5788-8644v. I 3930033-000039 District Attorney. Mr. Weinberg told me that he was unable to take a position on the Post's motion without first reviewing it and reserved the right to file an opposition, if necessary. 11. On December 21, 2018, the Post filed a motion requesting an order unsealing the appellate briefs and directing the Manhattan District Attorney's Office to produce copies with the names of victims redacted (the "December 21 Motion"). 12. On or about December 28, 2018, the Manhattan District Attorney's Office filed an affirmation in response to the Post's motion, signed by Assistant District Attorney Karen Friedman Agnifilo and dated December 28, 2018 (the "DA Affirmation"). A true and correct copy of the Affirmation is annexed hereto as Exhibit E. 13. On January 2, 2019, I spoke with Ms. Friedman Agnifilo to discuss the DA Affirmation. Ms. Friedman Agnifilo told me that there had been a miscommunication by Mr. Frost and that the District Attorney's Office did oppose the December 21 Motion. Ms. Friedman Agnifilo also told me that, in the view of the District Attorney's Office, the Post should give notice of their motion to unseal the appeal briefs to the prosecutors in Florida that handled the prosecution that led to Mr. Epstein's conviction for solicitation of prostitution from a minor. The Post disagrees with that position but nevertheless decided to moot any procedural issues related to requirements to notify the Florida prosecutors. Ms. Friedman Agnifilo subsequently informed me that the agency in Florida responsible for Mr. Epstein's prosecution was the Palm Beach County State Attorney's Office. 14. On January 3, 2019, I received an email from Mr. Weinberg stating that "after consideration of your request for the unsealing of the appellate briefs with redactions of certain identities, we take no position on behalf of Mr. Epstein." A true and correct copy of that email is annexed hereto as Exhibit F. 4840-5788-8644v. l 3930033-000039 15. On January 4, 2019, the Post filed a letter with this Court voluntarily withdrawing the December 21 Motion without prejudice to refile in order to moot the procedural issues raised by the Manhattan District Attorney's Office with respect to furnishing notice to prosecutors in Florida. A true and correct copy of that letter is annexed as Exhibit G. 16. On or about January 10, 2019, I contacted the Palm Beach County State Attorney's Office to inform it of the Post's intention to file a motion to unseal the appellate briefs and to inquire about where to send a copy of the motion. A member of the Office of State Attorney David Aronberg instructed me to send a digital copy of the motion to e­ postconviction@sa15.org and to send a paper copy to the State Attorney's main offices. 17. On or about January 10 and January 11, 2019, I spoke with Sarah J. Schall, Special Counsel to the U.S. Attorney in the Southern District of Florida, to inform her Office of the Post's intention to file a motion to unseal the appellate briefs and to inquire about where to send a copy of the motion. Ms. Schall instructed me to send a digital copy of the motion papers to her email address and to forward hard copies to Dexter Lee. Dated: New York, New York January 11, 2019 4840-5788-8644v.J 3930033-000039 EXHIBIT A Cops worked to put serial sex abuser in prison. Prosecutors worked to cut him a break BY JULIE K. BROWN NOV. 28, 2018 PERVERSION of JUSTICE A decade before #Me Too, a multimillionaire sex offender from Florida got the ultimate break. Palm Beach, Florida November 2004 Jane Doe Michelle Licata climbed a narrow, winding staircase, past walls covered with photographs of naked girls. At the top of the stairwell was a vast master bed and bath, with cream-colored shag carpeting and a hot pink and mint green sofa. The room was dimly lit and very cold. There was a vanity, a massage table and a timer. A silver-haired man wearing nothing but a white towel came into the room. He lay facedown on a massage table, and while talking on a phone, directed Licata to rub his back, legs and feet. Micelle Licata, is one of the over 100 middle school and high school-aged girls that Palm Beach billionaire, Jeffrey Epstein, is accused of sexually assaulting. Licata, now an adult living near Nashville, recalls her experience with Epstein at his Palm Beach mansion while she was a sophomore at Royal Palm Beach High School. EMILY MICHOT EMICHOT@MIAMIHERALD.COM After he hung up, the man turned over and dropped his towel, exposing himself. He told Licata to get comfortable and then, in a firm voice, told her to take off her clothes. At 16, Licata had never before been fully naked in front of anyone. Shaking and panicked, she mechanically pulled off her jeans and stripped down to her underwear. He set the timer for 30 minutes and then reached over and unsnapped her bra. He then began touching her with one hand and masturbating himself with the other. "I kept looking at the timer because I didn't want to have this mental image of what he was doing," she remembered of the massage. "He kept trying to put his fingers inside me and told me to pinch his nipples. He was mostly saying 'just do that, harder, harder and do this .... ' " After he ejaculated, he stood up and walked to the shower, dismissing her as if she had been in history class. It wasn't long before a lot of Licata's fellow students at Royal Palm Beach High School had heard about "a creepy old guy" named Jeffrey who lived in a pink waterfront mansion and was paying girls $200 to $300 to give him massages that quickly turned sexual. Eventually, the Palm Beach police, and then the FBI, came knocking on Licata's door. In the police report, Licata was referred to as a Jane Doe in order to protect her identity as a minor. Palm Beach home of registered sex offender, Jeffrey Epstein. PEDRO PORTAL PPORTAL@MIAMIHERALD.COM There would be many Jane Does to follow: Jane Doe No. 3, Jane Doe No. 4, Jane Does 5, 6, 7, 8 - and as the years went by- Jane Does 102 and 103. Long before #MeToo became the catalyst for a women's movement about sexual assault - and a decade before the fall of Harvey Weinstein, Bill Cosby and U.S. Olympic gymnastics doctor Larry Nassar - there was Jeffrey Edward Epstein. Epstein, a multimillionaire hedge fund manager whose friends included a constellation of entertainers, politicians, business titans and royalty, for years lured teenag�girls to his Palm Beach mansion as P-art of a cult-like sex P-Y-ramid scheme, police in the town of Palm Beach found. The girls arrived, sometimes by taxi, for trysts at all hours of the day and night. Few were told much more than that they would be paid to give an old man a massage - and that he might ask them to strip down to their underwear or get naked. But what began as a massage often led to masturbation, oral sex, intercourse and other sex acts, police and court records show. The alleged abuse dates back to 2001 and went on for years. Palm Beach multimillionaire Jeffrey Epstein is a free man, despite sexually abusing dozens of underage girls according to police and prosecutors. His victims have never had a voice, until now. BY EMILY MICHOT ill I JULIE K. BROWN ill In 2007, despite ample physical evidence and multiple witnesses corroborating the girls' stories, federal prosecutors and Epstein's lawyers quietly put together a remarkable deal for Epstein, then 54. He agreed to plead guilty to two felony prostitution charges in state court, and in exchange, he and his accomplices received immunity from federal sex-trafficking charges that could have sent him to prison for life. He served 13 months in a private wing of the Palm Beach County stockade. His .alkged co-consP-irators, who helped schedule his sex sessions, were never prosecuted. The deal, called a federal non-prosecution agreement, was sealed so that no one - not even his victims - could know the full scope of Epstein's crimes and who else was involved. The U.S. attorney in Miami, Alexander Acosta,-™..P-ersonall y: involved in the negotiations, records, letters and emails show. Acosta is now a member of President Donald Trump's Cabinet. As U.S. secretary of labor, he has oversight over international child labor laws and human trafficking and had recently been mentioned as a possible successor to farmer U.S. Attorney General Jeff Sessions, who resigned under pressure in early November. It was reported on Thursday, a day after this story posted online, that he was no longer in the running. C Alex Acosta, Federal Attorney, speaks during a press conference celebrated during the opening sesion of South Florida Anti-Gang Summit at Miami Hilton Hotel on Sept. 29, 2008 in Miami, Fl. (Cristobal Herrera/Sun Sentinel/TNS) CRISTOBAL HERRERA TNS The Miami Herald anal y: zed thousands of P-ages of court records and lawsuits, witness depositions and newly released FBI documents, and also identified more than 80 women who say they were victimized. They are scattered around the country and abroad. Until now, those victims - today in their late 20s and early 30s - have never spoken publicly about how they felt shamed, silenced and betrayed by the very people in the criminal justice system who were supposed to hold Epstein accountable. "How come people who don't have money get sent to jail - and can't even make bail - and they have to do their time and sit there and think about what they did wrong? He had no repercussions and doesn't even believe he did anything wrong," said Licata, now 30. Micelle Licata, is one of the over 100 middle school and high school-aged girls that Palm Beach billionaire, Jeffrey Epstein, is accused of sexually assaulting. Licata, now an adult living near Nashville, recalls her experience with Epstein at his Palm Beach mansion while she was a sophomore at Royal Palm Beach High School. EMILY MICHOT EMICHOT@MIAMIHERALD.COM Licata is among 36 women who were officially identified by the FBI and the U.S. Attorney's Office as victims of Epstein, now 65. But after the FBI case was closed in 2008, witnesses and alleged victims testified in civil court that there were hundreds of girls who were brought to Epstein's homes, including girls from Europe, Latin America and former Soviet Republic countries. But Acosta and Epstein's armada of attorneys - Harvard professor Alan Dershowitz, Jay Lefkowitz, Gerald Lefcourt, Jack Goldberger, Roy Black, Guy Lewis and former Whitewater special prosecutor Kenneth Starr - reached a consensus: Epstein would never serve time in a federal or state prison. READ NEXT I LOCAL I Sex abuser Jeffrey Epstein was surrounded by powerful people. Here's a sampling NOVEMBER 28, 2018 8:00 AM ------------- ----·---- ---·--·- --· ----------·----- POLICE UNDER PRESSURE There were really just two people willing to risk their careers to go after Epstein: Palm Beach Police Chief Michael Reiter and Detective Joseph Recarey. For Reiter, business tycoon Jeffrey Epstein wasn't any more formidable than any of the other 8,000 or so wealthy and powerful people living on the island. Police had handled sensational cases involving wealthy residents before - from the murders of heiresses to the rape case involving William Kennedy Smith, of the Kennedy family. The easternmost town in Florida, Palm Beach is a 10.4-square-mile barrier island between the Intracoastal Waterway and the Atlantic Ocean populated by some of the richest people in the country. President Trump has his "winter White House" in Palm Beach, and the town makes news as much for its glitz as it does for its unusual efforts to preserve its well-mannered image, like banning shirtless Joggers. But it was a little surprising, even to Reiter, to learn that one of its residents had a revolving door of middle and high school girls coming to his gated compound throughout the day and night. In their first on-the-record media interviews about the case, Reiter and Recarey revealed new details about the investigation, and how they were, in their view, pressured by then-Palm Beach State Attorney Barry Krischer to downgrade the case to a misdemeanor or drop it altogether. Former Palm Beach County Police Detective Joe Recarey was the lead detective on the solicitation-of-minors case against billionaire Jeffrey Epstein. EMILY MICHOT EMICHOT@MIAMIHERALD.COM Between March of 2005 -when the case was opened -and seven months later, when police executed a search warrant at Epstein's home, Recarey had identified 21 possible victims, according to a copy of the unredacted police report obtained by the Herald. By the time police felt they had enough evidence to arrest Epstein on sex charges, they had identified about 3 5 possible underage victims and were tracking down at least a dozen more, the police report said. "I was surprised at how quickly it snowballed. I thought at some point there would be a last interview, but the next victim would supply me with three or four more names and the next one had three or four names and it just kept getting bigger and bigger,'' Recarey said. By then, word had gotten back to Epstein from some of the girls that they had been questioned by police. Epstein hired famed lawyer Alan Dershowitz. "Alan Dershowitz flew down and met privately with Krischer," Recarey said. "And the shenanigans that happened, I don't think I've ever seen or heard of before." Police reports show that Epstein's private investigators attempted to conduct interviews while posing as cops; that they picked through Reiter's trash in search of dirt to discredit him; and that the private investigators were accused of following the girls and their families. In one case, the father of one girl claimed he had been run off the road by a private investigator, police and court reports show. Support investigative journalism The Miami Herald obtained thousands of FBI and court records, lawsuits, and witness depositions, and went to federal court in New York to access sealed documents in the reporting of "Perversion of Justice." The Herald also tracked down more than 60 women who said they were victims, some of whom had never spoken of the abuse before. Your digital subscription, starting at $0.99 for the first month, supports investigative journalism like this. CLICK TO SUBSCRIBE Several of the girls said they felt intimidated and frightened by Epstein and Sarah Kellen, the millionaire's assistant and alleged scheduler of massages, who warned them not to talk to police, according to the police report. Dershowitz, in an interview with the Herald, said he had nothing to do with gathering background on the girls - or in directing anyone to follow the police, or the girls and their families. "I'm not an investigator. My only job was to negotiate and try the case when it comes to trial,'' he said. He nevertheless convinced Krischer that the girls would not be credible on the witness stand, according to Reiter and Recarey. The defense team's investigators compiled dossiers on the victims in an effort to show that Epstein's accusers had troubled pasts. Dershowitz met with Krischer and Recarey, sharing with them the results of an investigation into one of the girls, described by Dershowitz as "an accomplished drama student" who hurled profanities at his investigator at "a furious pace." 10/27/99 - OPINION - Barry Krischer; P.B.Co. State Attorney. (AM) "Our investigation had discovered at least one of her websites and I am enclosing some examples ... the site goes on to detail, including photos, her apparent fascination with marijuana, " Dershowitz wrote in an undated letter to Recarey. He also disputed the claim that one of the defense team's private investigators had misrepresented himself as a police officer. Recarey stood his ground. "His attorneys showed us a MySpace page where one of the-girls was holding a beer in her hand, and they said, 'oh look, she is underage drinking,' " Recarey recalled. "Well, tell me what teenager doesn't? Does that mean she isn't a victim because she drank a beer? Basically, what you're telling me is the only victim of a sexual battery could be a nun." Krischer and the lead state prosecutor on the case, Assistant State Attorney Lanna Belohlavek, began to dodge Recarey and Reiter's phone calls and emails, and they dragged their feet on approving subpoenas, Reiter and Recarey said. "Early on, it became clear that things had changed, from Krischer saying, 'we'll put this guy away for life,' to 'these are all the reasons why we aren't going to prosecute this,' " Reiter said. Krischer, who is now retired and in private practice, did not respond to multiple requests from the Herald for comment. Belohlavek also did not respond to an email sent to her office. "It became apparent to me that some of our evidence was being leaked to Epstein's lawyers, who began to question everything that we had in our probable cause affidavit," Reiter said. The day of the search on Oct. 20, 2005, they found that most of Epstein's computer hard drives, surveillance cameras and videos had been removed from the house, leaving loose, dangling wires, according to the police report. But the girls' description of the house squared with what detectives found, right down to the hot pink couch and the dresser drawer of sex toys in Epstein's bathroom. Reiter said his own trash was disappearing from his house, as his life was put under Epstein's microscope. Private investigators hired by Epstein's lawyers even tracked down Reiter's grade school teachers, the former chief said. Questions were raised about donations that Epstein had made to the police department, even though Reiter had returned one of the donations shortly after the investigation began. Recarey, meanwhile, said he began to take different routes to and from work, and even switched vehicles because he knew he was being tailed. "At some point it became like a cat-and-mouse game. I would stop at a red light and go. I knew they were there, and they knew I knew they were there. I was concerned about my kids because I didn't know if it was someone that they hired just out of prison that would hurt me or my family," Recarey said. Despite relentless political pressure, Reiter and Recarey soldiered on, and their determination yielded evidence that supported most of the girls' allegations, the former cops said. They had phone records that showed Epstein and his assistant, Kellen, had called many of the girls. Epstein's flight logs showed that the calls were made when Epstein was in Palm Beach. They obtained dozens of message pads from his home that read like a who's who of famous people, including magician David Copperfield and Donald Trump, an indication of Epstein's vast circle of influential friends. There were also messages from girls, and their phone numbers matched those of many of the girls Recarey had interviewed, Recarey said. They read: "Courtney called, she can come at 4," or "Tanya can't come at 7 p.m. tomorrow because she has soccer practice." They also found naked photographs of underage girls in Epstein's closet, Recarey said. There were also witnesses: Two of Epstein's butlers gave Recarey sworn interviews, confirming that young girls had been coming and going at the house. One of the butlers, Alfredo Rodri gu ez, told Recarey that when he was tasked with cleaning up the master bath after Epstein's sessions with the girls, he often discovered sex toys. Once, he accidentally stumbled on a high school girl, whom he identified, sleeping naked in Epstein's spa, he testified in a 2009 court deposition. Rodriguez said he was given the job of paying the girls, telling Recarey that he was "a human ATM machine" because he was ordered by Epstein to keep $2,000 on him at all times. He was also assigned to buy the girls gifts. Rodri gu ez gave Recarey copies of pages from a book that Epstein and his staff kept with the names and phone numbers for many of the Palm Beach County girls, Recarey said. Rodriguez, however, held onto the bulk of Epstein's "little black book," and in November 2009 tried to sell it for $50,000 to an undercover FBI agent posing as a victim's lawyer. He was arrested and sentenced in 2012 to federal prison, and died three years later following an illness. The book - listing personal phone numbers for a cavalcade of Epstein's powerful friends and celebrities - eventually became public as part of a civil lawsuit. It listed more than 100 female names and phone numbers under the headings "massage" in every city where Epstein had homes. In May 2006, Recarey drew up probable cause affidavits, charging Epstein, two of his assistants and one recruiter with sex-related crimes. Instead, Krischer took what Recarey said was the unusual step of referring the case to a state grand jury. Epstein was indicted in state court on a minor charge of solicitation of prostitution. Recarey said Krischer told him he didn't believe Epstein's accusers, and only two of them were called before the state grand jury investigating the case - even though police had lined up more than a dozen girls and witnesses at that time. Believing that the case had been tainted, Reiter - that same month, May 2006 - took a very public stance against Krischer, writing a letter, which was released to the news media, calling on Krischer to remove himself from the case. The chief then referred it to the FBI, which opened its own investigation in July 2006, FBI records show. Reiter said he was effectively blackballed in some Palm Beach circles as a result of going over Krischer's head, and their relationship, once strong, would never be the same. Reiter has no regrets about what he did. "There are challenges here that don't exist in a lot of other places because of the affluence in the community, but the only way I could approach this case was that none of that matters. The truth is still the truth. The facts are the facts. Everybody is treated the same." In the years that followed, several of the victims obtained lawyers and filed civil lawsuits against Epstein. About two dozen lawsuits were filed, starting in 2008. The early cases were particularly brutal for his victims, the court records show. The girls faced fierce grilling from another pack of Epstein's civil attorneys, who questioned them about their boyfriends, drinking, drug use, social media posts, their parents and even their medical histories. One girl was asked about her abortions, and her parents, who were Catholic and knew nothing about the abortions, were also deposed and questioned. Licata said the questions from Epstein's civil lawyers were so intimate that she became paranoid that people were following her. "His lawyers were just in my life inside and out. They asked if I had a baby, if I had an abortion, 'did you sleep with 30 different guys' and 'do you think that played a part?' I said, 'you're going to come at me like that when you represent a guy who is doing this to hundreds of girls? How do you sleep at night?' " BROOKLYN TO PALM BEACH Jeffrey Epstein was born in Brooklyn, the son of a New York parks department worker. In one of several depositions he gave as part of the lawsuits filed against him, he said he attended the Cooper Union school for the advancement of science and art and then studied physics at New York University. But he never obtained a degree, instead going on to teach at the Dalton School, an elite K-12 private academy on Manhattan's Upper East Side. Various news profiles over the years have speculated about how he made his vast fortune, calling him an "International Moneyman of Mystery" and "The Talented Mr. Epstein."
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KMBT_C654e-20190114185410 - Epstein Files Document HOUSE_OVERSIGHT_016420

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KMBT_C654e-20190114185410 - Epstein Files Document HOUSE_OVERSIGHT_016420 | Epsteinify