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Unreported Criminal Histories and Mental Health Problems of the Witnesses Relied on in the Police Report and Probable Cause Affidavits. Virtually every witness relied on to support the Police Report and the probable cause affidavit has a background that casts significant doubt on whether the witness is sufficiently credible to support a finding of probable cause, let alone to sustain what would be the State’s burden of proof at a trial. (Indeed, nearly all the witnesses, and certainly those deemed complainants, were friends, which undercuts any claim that one story corroborates another.) Though this evidence was submitted to the PBPD, none of it was included in the Police Report, the probable cause affidavit, or released to the public. Below we address solely the omitted criminal histories. Following that, we list other factors that make each witness unworthy of belief and incapable of withstanding cross-examination at trial — all of which was previously provided to the PBPD but omitted from the Police Report, the probable cause affidavit and the public disclosure. 6. Juan Alessi: While the Police Report (at page 57) and the probable cause affidavit (at page 21) contain assertions by Alessi which allegedly support the bringing of criminal charges, omitted is the evidence revealing Alessi’s evident mental instability; prior criminal conduct against Epstein; and bias towards Epstein. As the PBPD well knew, in 2003, Alessi was filmed taking money from Epstein’s home. After being caught on videotape unlawfully entering Epstein’s home and stealing cash from a briefcase, Alessi admitted to the PBPD that he entered the house unlawfully on numerous occasions, stealing cash and attempting to steal Epstein’s licensed handgun (which in fact went missing). Officers assigned to the investigation prepared a report detailing Alessi’s confession. Also known to the PBPD, but omitted from the Police Report, is that Alessi claimed he intended to steal the gun in order to kill himself. Though this information is clearly material to any determination of credibility, and was specifically known to Det. Recarey at the time the Police Report and probable cause affidavits were written, it was omitted. 7. While the Police Report and probable cause affidavit rely on statements of the father of omitted is evidence, known to the PBPD, that casts doubt on credibility and sustainability as a witness. Omitted from the Police Report and probable cause affidavit is ederal fraud conviction, which defense investigators discovered and turned over to the PBPD during the course of the investigation. erved 21 months in federal prison for his offense. 8. While the Police Report and probable cause affidavit rely on statements of the step-mother of PI omitted is evidence, known to the PBPD that casts doubt on her credibility. Omitted from the Police Report and the probable cause affidavit is state conviction for identity fraud — criminal use of identification information. This information, uncovered by defense investigators, was also turned over to the PBPD during the course of the investigation. 4 Public Records Request No. 19-372 DOJ-OGR-00033211