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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Mark Epstein on Monday, September 21, 2009, at 11:00 a.m., at:
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this //4'day of August, 2009 to all those on the
attached Service List.
EFTA00725584
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale. • a 33301
Tel:
Fax:
Email
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reporters
EFTA00725585
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3 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
v. No. 17 Civ. 00616 (JGK)
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
and
Defendants.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
OF JEFFREY EPSTEIN
PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil
Procedure, counsel for Plaintiff, will take a videotaped deposition of the
Defendant as set forth below:
NAME: Jeffrey Epstein
DATE AND TIME: August 21, 2018 at 10:00 a.m.
LOCATION: Boies Schiller & Flexner, LLP
The videotaped deposition will be taken upon oral examination before Magna Legal
Services, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
' Plaintiff originally filed this action under the pseudonym but is now proceeding
under her real name.
I
EFTA00285620
The video operator shall be provided by Magna Legal Services. This deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the rules of this Court.
Dated: August 10, 2018.
BOLES SCHILLER FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller Flexner LLP
Bradley J. Edwards, Esq. (Pro Hac Vice)
Stanley Pottinger, Esq.
EOMPaul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
2 This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2
EFTA00285621
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of August, 2018, I served the attached
PLAINTIFFS NOTICE OF TAKING VIDEOTAPED DEPOSITON OF WITNESS JEFFREY
EPSTEIN via Email to the following counsel of record.
Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
Counselfor Jeffrey Epstein, and
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON MORGAN & FOREMAN, P.C.
Counselfor Ghislaine Maxwell
By: /s/ SigridMcCawley
Sigrid McCawley
3
EFTA00285622
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UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No: 10-80447-cv-Marra/Johnson
C. L.
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSMON OF:
NAME: DATE AND TIME: - LOCATION:
Maritza Milagros Vasquez May 18, 2010 Intelligent Office, 701 Brickell
10:00 AM Avenue, Suite 1550, Miami,
FL 33131
upon an oral examination before Videograpber and a Notary Public or officer authorized by law
to take depositions in the State of Florida. The oral examination will continue from day to day until
completed. The depositions are being taken for purposes of discovery, for use at trial or are being
taken for such other purposes as are permitted under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed thisZ
day of April 2010 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL .33401; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-
(561) 515-
By:
Spencer Kuvin, Esq.
Florida Bar No: 089737
EFTA00611587
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1 pages
I
Sent Mon 8/23/2004 8:53:49 PM
Subject talking
Ghislaine,
Just picked up your call. I'm in 11th hour deposition related stuff and
surrounded by fabric experts, lawyer, etc. I'm stealing a second to write this.
Cannot call today. Traveling to SF for the day on Tues and will try to call you
from the airport after I check in.
xoxoxox
I
EFTA_R1_01279280
EFTA02332966
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Page I
1 UNITED STATES BANKRUPTCY COURT
SOUTHER DISTRICT OF FLORIDA
2 FORT LAUDERDALE DIVISION
3
4 IN RE: NO.: 09-34791-RBR
5 ROTHSTEIN ROSENFELDT ADLER, P.A.
6
7
8 VIDEOTAPED
9 DEPOSITION
10 OF
11 JOHN JACK SCAROLA
12
13
14
15 350 East Las Olas Boulevard
Fort Lauderdale, Florida
16 July 2, 2013
Scheduled for 10:00 a.m.
17 Commencing at 10:07 a.m. to 5:23 p.m.
18
19
20
21
22
23
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130196
Page 2
1 UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
2 FORT LAUDERDALE DIVISION
3
4 IN RE: CHAPTER 7
5
BANYON 1030-32, LLC CASE NOS: 10-36691-RBR
6 BANYON INCOME FUND, L.P. 11-40929-RBR
7 Debtors. Jointly Administered Under
Case No. 10-33691-RBR
8
/
9
10
11
12 VIDEOTAPED
13 DEPOSITION
14 OF
15 JOHN JACK SCAROLA
16
17
18
19 350 East Las Olas Boulevard
Fort Lauderdale, Florida
20 July 2, 2013
Scheduled for 10:00 a m.
21 Commencing at 10:07 a.m. to 5:23 p.m.
22
23
24
25
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130197
Page 3
1 APPEARANCES:
2 On behalf of TD Bank, N.A.:
WILLIAM O.L. "WEN" HUTCHINSON, Esquire
3 JOSEPH SHEERIN, Esquire
MCGUIREWOODS
4 201 North Tyron Street
Suite 3000
5 Charlotte, North Carolina 28202
6 On behalf Herbert Stettin, Trustee:
JOHN H. GENOVESE, Esquire
7 MICHAEL A. FRIEDMAN, Esquire
GENOVESE JOBLOVE & BATTISTA, P.A.
8 100 Southeast Second Street
44th Floor
9 Miami, Florida 33131
-and-
10 DAVID GAY, Esquire
BERGER SINGERMAN
11 350 East Las Olas Boulevard
Suite 1000
12 Fort Lauderdale, Florida 33301
13 On behalf of Robert Furr, Trustee:
JASON S. RIGOLI, Esquire
14 FURR & COHEN, P.A.
One Boca Place, Suite 337W
15 2255 Glades Road
Boca Raton, Florida 33431
16
On behalf of the Plaintiffs:
17 ADAM MOSKOWITZ, Esquire
KOZYAK TROPIN & THROCKMORTON, P.A.
18 2525 Ponce de Leon Boulevard
Ninth Floor
19 Miami, Florida 33131-2335
20 On behalf of the Plaintiffs:
William Scherer, Esquire
21 CONRAD & SCHERER, LLP
633 South Federal Highway
22 Eighth Floor
Fort Lauderdale, Florida 33301
23
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130198
Page 4
1 CONT. APPEARANCES:
2 On behalf of Unsecured Creditors Committee:
MICHAEL J. GOLDBERG, Esquire
3 350 East Las Olas Boulevard
Suite 1600
4 Fort Lauderdale, Florida 33301-2229
5 On behalf of Morse Operations and
The Estate of Ed Morse:
6 JOHN M. MULLIN, Esquire
TRIPP SCOTT
7 110 Southeast Sixth Street
Fifteenth Floor
8 Fort Lauderdale, Florida 33301
9
10 ALSO PRESENT:
11 Patricia Diaz, FPR, RPR
12 Dean J. Chimerakis, Videographer
Custom Video Services, Inc.
13
14
15
16
17
18
19
20
21
22
23
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130199
Page 5
1 INDEX
2 WITNESS: PAGE
3 JOHN JACK SCAROLA
4 DIRECT EXAMINATION BY MR. HUTCHINSON 7
CROSS-EXAMINATION BY MR. GENOVESE 173
5 CROSS-EXAMINATION BY MR. MOSKOWITZ 216
6
7
8 EXHIBITS
9 -
10 NO. DESCRIPTION PAGE
11 Exhibit No. 1 Subpoena 7
12 Exhibit No. 2 Subpoena for Christian 9
Searcy
13
Exhibit No. 3 Transcript of May 17, 2013 48
14 Hearing
15 Exhibit No. 4 Plaintiff's First Request 68
for Production of Documents
16 to TD Bank
17 Exhibit No. 5 TD Bank Victims Notice of 79
Filing Expert Disclosures
18
Exhibit No. 6 Time Summary 81
19
Exhibit No. 7 Conspiracy Chart 111
20
Exhibit No. 8 Statute 768.72 124
21
Exhibit No. 9 Statute 768.73 148
22
Exhibit No. 10 Handwritten Notes 163
23
Exhibit No. 11 Handwritten Notes 168
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130200
Page 6
1 THE VIDEOGRAPHER: Today's date is July 2nd,
2 2013. The time is approximately 10:10 a.m. Eastern
3 Standard Time. We are here to videotape the
4 deposition of John Jack Scarola in regard to
5 Rothstein, Rosenfeldt, Adler, PA, Case 09-34791
6 BKCRVR.
7 The court reporter is Patty Diaz with
8 Ouellette and Mauldin Court Reporting. My name is
9 Dean Chimerakis, videographer, with Custom Video
10 Services of Miami.
11 Will counsel please state your appearance for
12 the record?
13 MR. HUTCHINSON: Wayne Hutchinson with
14 McGuireWoods on behalf of TD Bank, N.A., and with
15 me is Joe Sheerin.
16 MR. GENOVESE: John Genovese, Genovese,
17 Joblove and Battista on behalf of Herb Stettin.
18 Along with me is my colleague, Michael Friedman.
19 MR. RIGOLI: Jason Rigoli, Furr & Cohen on
20 behalf of Robert Furr, Chapter 7 Trustee for Banyon
21 1030-32 and Banyon Income Fund.
22 MR. MOSKOWITZ: Adam Moskowitz, Bill Scherer
23 and Javi Lopez on behalf of the plaintiffs in the
24 case.
25 MR. MULLIN: John Mullin from Tripp, Scott on
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130201
Page 7
1 behalf of the Estate of Ed Morse and Morse
2 Operations, Inc.
3 MR. GOLDBERG: Mike Goldberg on behalf of the
4 Creditors Committee.
5 MR. GAY: David Gay with Berger Singerman
6 counsel on behalf of Herbert Stettin.
7 Thereupon,
8 JOHN SCAROLA
9 was called as a witness and, having been duly sworn, was
10 examined and testified as follows:
11 THE WITNESS: I do.
12 DIRECT EXAMINATION
13 BY MR. HUTCHINSON:
14 Q. Good morning, Mr. Scarola. We met before the
15 deposition. Would you please state your name for the
16 record?
17 A. Good morning. My name is John Scarola. I am
18 also most commonly known as Jack.
19 Q. Mr. Scarola, I will show you what I marked as
20 Exhibit 1. Do you recognize Exhibit 1?
21 (Exhibit No. 1, Subpoena, was marked for
22 identification.)
23 A. It appears to be a copy of the subpoena for
24 this deposition that was served upon my office and
25 accepted at my direction.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130202
Page 8
1 BY MR. HUTCHINSON:
2 Q. And are you appearing here today pursuant to
3 this subpoena?
4 A. I am.
5 Q. And this subpoena includes a document request,
6 does it not?
7 A. It does.
8 Q. And have you produced all documents that are
9 responsive to the request included therein?
10 A. I believe I have.
11 Q. Does that include some documents that you have
12 brought with you here today?
13 A. That is correct.
14 Q. Based on what was previously produced and what
15 you brought here today, you believe that all documents
16 responsive to these requests have now been provided.
17 Correct?
18 A. I don't have personal knowledge of the
19 production that was not made by me. I am told that you
20 have already received duplicate copies of most of the
21 materials that I brought today, but I have brought with
22 me all of those materials in my possession that are
23 responsive to the subpoena.
24 Q. And you are fine with us looking through those
25 materials to confirm that we have them and if not,
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130203
Page 9
1 making any copies that we need to make so that we have
2 them for our records?
3 A. Yes. I know that there are documents that are
4 included in the group of documents that I brought this
5 morning that were not produced to you because they are
6 my personal notes with regard to my review of the other
7 materials.
8 Q. But you are not aware of any additional
9 materials that either have not been provided or are not
10 with you here today?
11 A. I am not.
12 Q. Let me show you what I marked -- is marked as
13 Exhibit 2.
14 (Exhibit No. 2, Subpoena for Christian Searcy,
15 was marked for identification.)
16 A. Yes, sir.
17 BY MR. HUTCHINSON:
18 Q. Do you recognize Exhibit 2, sir?
19 A. I do.
20 Q. What is Exhibit 2?
21 A. Exhibit 2 is a copy of a subpoena that was
22 accepted by my office on behalf of Christian Searcy and
23 I have seen a copy of this subpoena as well.
24 Q. And am I correct that this subpoena also
25 includes certain document requests?
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130204
Pagc 10
1 A. It does.
2 Q. And we have not received a separate response
3 to this subpoena from your law firm. Is your document
4 production individually supposed to respond to this
5 subpoena as well?
6 A. It is.
7 Q. So as we sit here today, you have no knowledge
8 of additional documents responsive to the request,
9 including Exhibit 2, that are responsive therein that
10 have not either been provided to us previously or are
11 not in the materials that you brought here today?
12 A. That is correct. Certainly, it's possible
13 that I may have overlooked something, but I don't think
14 SO.
15 Q. Mr. Scarola, in what fields are you an expert?
16 A. I am a trial lawyer who has been practicing in
17 the area of litigation since 1972. I am Board-certified
18 in personal injury and in business litigation as well
19 and I believe that both certifications have been in
20 place since they were offered by the Florida Bar.
21 Q. And if you were going to list the fields in
22 which you believe that you are an expert, what fields
23 how would you describe those fields and what would they
24 be?
25 A. Well, for purposes of the deposition today, I
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130205
Rigel]
1 have been asked to express opinions with regard to the
2 punitive damage value of claims against TD Bank and I
3 present myself as having sufficient expertise in that
4 area to express those opinions.
5 Q. So it's your understanding that your opinions
6 in this matter are limited to the value of potential
7 punitive damages claims against TD. Is that correct?
8 A. That certainly is the primary focus of what I
9 have been asked to do, and while I may have formed some
10 tangential opinions that relate to that primary area,
11 that is the focus of what I have done.
12 Q. What qualifies you as an expert on punitive
13 damages and the values of punitive damages claims?
14 A. The total of 40 years experience that I have
15 had litigating both criminal and civil cases, including
16 many punitive damages claims.
17 Q. At what point during that 40-year career did
18 you become an expert on valuating punitive damages
19 claims?
20 A. I cannot tell you the point in time at which
21 someone would have independently recognized my
22 expertise. It has been an evolving process, so that's a
23 question that I can't answer for you, except to tell you
24 that it is my personal assessment that I am certainly
25 there now.
OUELLETTE & MAUI DIN COURT REPORTERS,INC.
EFTA01130206
Page 12
1 Q. Are there any specific factors that you
2 believe makes you qualified to be an expert on the
3 valuation of punitive damages claims other than your
4 general experience?
5 A. Yes. It is an area of the law that I have
6 studied. It is an area of the law that I have focused
7 study upon. That is, I am sure that over the course of
8 particularly the last 35 years I have taken CLE courses
9 that have dealt with the topic of punitive damages as
10 well as having taught multiple courses dealing with the
11 topic of punitive damages.
12 So, it is as a consequence of practical
13 experience, formal education and self-study that I have
14 accumulated the degree of expertise that I have in this
15 area.
16 Q. Let's talk about the CLE courses that you have
17 taught that deal with the valuation of punitive damages
18 claims. Can you please tell me about those courses,
19 their titles and when they were offered?
20 A. I'm sorry, but I cannot give you the course
21 titles nor can I tell you the specific dates on which
22 the courses were offered.
23 What I can tell you is that I have lectured on
24 both the state and local level on the topic of punitive
25 damages and have also been invited to give lectures on
OUELLETTE & MA LDIN COURT REPORTERS, INC.
EFTA01130207
PagcB
1 punitive damages in front of at least one other state
2 Bar Association.
3 Q. What state Bar Association was that that you
4 are referring to?
5 A. Ohio.
6 Q. Were they the sponsor of the continuing
7 education class?
8 A. They were.
9 Q. And where was that lecture?
10 A. It actually occurred when that Bar Association
11 met in Palm Beach County.
12 Q. And when was that?
13 A. I can't give you the date.
14 Q. Was it in the last five years?
15 A. I'm not sure.
16 Q. What's your best estimate of when that would
17 have been?
18 A. Approximately, five years ago.
19 Q. And did you prepare materials for that CLE
20 presentation?
21 A. I don't know whether I prepared materials
22 specifically for that CLE presentation or whether I
23 relied upon materials previously prepared and having
24 lectured on the topic prior to that lecture.
25 Q. Would you still have the materials that you
OUELLETTE & NIAULDIN COURT REPORTERS, INC.
EFTA01130208
Page 14
1 would have used in these past lectures?
2 A. Probably some of them.
3 Q. Is the information contained in those
4 materials anything that you relied upon in forming the
5 opinions in this case?
6 A. The information contained within those
7 materials include principles that I relied upon in
8 formulating my opinions in this case, I think would be a
9 more accurate way to state the relationship between
10 those materials and my opinion.
11 Q. And to the extent that you can find any of
12 those ---
13 A. You've got them.
14 Q. Okay. Are those materials with you here
15 today?
16 A. They are. If they exist, they are in that
17 box.
18 Q. Thank you very much.
19 A. You are welcome.
20 Q. Other than the lectures at the Ohio State Bar
21 Association, were your other CLE lectures all
22 sponsored -- were the classes all sponsored by the
23 Florida Bar Association?
24 A. No.
25 Q. Who were the other CLE classes sponsored by
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130209
Pagc 15
1 wherein you lectured on punitive damages?
2 A. Palm Beach County Bar Association, Palm Beach
3 County Justice Association, Florida Justice Association.
4 Q. And over how many years did those lectures
5 occur?
6 A. Certainly within the past 20 years, and I
7 don't know that I can accurately narrow it down beyond
8 that. It's a topic that I have been dealing with
9 significantly over at least the last 20 years.
10 Q. Have you lectured on the punitive damages
11 aspect of the Florida Tort Reform Acts that were
12 implemented in the late 1990s?
13 A. I have.
14 Q. What would have been your topics on -- what's
15 been the subject matters of those lectures on those
16 topics?
17 A. The implications from both the legal and
18 practical standpoint of the legislative changes.
19 Q. And what do you recall about those
20 implications?
21 A. I recall that the Florida legislature has,
22 from time to time, been imposing various restrictions on
23 the common law ability to recover punitive damages.
24 Q. In your opinion, does the Florida Legislature
25 have the right to do that?
OUELLETTE & NIAULDIN COURT REPORTERS, INC.
EFTA01130210
Page 16
1 A. It is my personal opinion that the Florida
2 Legislature has a limited right to deal with imposing
3 restrictions on the ability to recover punitive damages,
4 that there are constitutional limitations on how those
5 restrictions may be imposed.
6 Q. What constitutional limitations are you
7 referring to?
8 A. The due process and equal protection clauses
9 of both the United States Constitution and the Florida
10 Constitution.
11 Q. Are you claiming -- is it your -- are you
12 offering an opinion in this matter that there is a
13 property right with respect to a punitive damages claim?
14 A. No. I am not offering that opinion. I am
15 assuming for purposes of the opinions that I will be
16 expressing today that the current legislative
17 limitations that have been imposed upon the ability to
18 recover punitive damages pass constitutional muster.
19 Q. They do pass constitutional muster?
20 A. I have assumed that for purposes of the
21 opinions that I am expressing today.
22 Q. So, you are not offering an opinion in this
23 matter that the current statutes limiting punitive
24 damage awards are somehow unconstitutional or not
25 applicable to this matter?
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130211
Pagc 17
1 A. I am not offering that opinion today.
2 Q. And you are not planning on offering that
3 opinion at the confirmation hearing?
4 A. I don't plan on offering that opinion at the
5 confirmation hearing, no.
6 Q. Let's go back. You talked about that you've
7 lectured on the practical implications of the new -- of
8 the punitive damages tort reform that was implemented in
9 the late 1990s. What is your understanding of the
10 practical implications of those reforms?
11 A. That really is a very broad question and I
12 would prefer that it be more focussed before I attempt
13 to answer it.
14 In what regard?
15 Q. Well, are there limits on the -- the amount of
16 punitive damages? Is it your understanding there are
17 limits on the amount of punitive damages that can be
18 recovered as a result of such reforms?
19 A. Yes, under some circumstances.
20 Q. And what are those circumstances?
21 A. Those that are specifically described in the
22 statute.
23 Q. Do you recall any of those circumstances
24 without referencing the statute?
25 A. I think I can recall some of them without
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130212
Pagc 18
1 referencing the statute. Certainly, if you want the
2 most accurate answer I am able to give you, I've got a
3 copy of the statute in the materials that have been
4 provided, and it would be easier to have it in front of
5 me. But if what you would like to do is test my memory,
6 you know, I will play that game with you.
7 Q. Well, we are not playing games.
8 A. Okay.
9 Q. But what do you recall about the statutory
10 limitations?
11 A. I recall that there are limitations that would
12 impose a three times compensatory damage limit under
13 some circumstances, limitations that impose a four time
14 compensatory damage limitation under some circumstances.
15 There is expressed statutory language that indicates
16 that there is no statutory limitation under other
17 circumstances, and I recall that there is specific
18 language in the statute that indicates that the statute
19 is primarily applicable to products liability claims.
20 Q. Are you offering an opinion in this matter
21 that the statutes are somehow not applicable to the
22 claims at issue?
23 A. It is my opinion that the circumstances of the
24 punitive damage claims against TD Bank take those damage
25 claims outside the statutory limitations.
OUELLETTE & NIAULDIN COURT REPORTERS, INC.
EFTA01130213
Pagc 19
1 Q. Is that -- is it your opinion that it's
2 outside the statutory limitations because they are not
3 product liability claims?
4 A. It's my opinion that they are outside the
5 statutory limitations for multiple reasons; one, because
6 they are not within those provisions of the statute that
7 impose limitations, but secondly, because the nature of
8 the misconduct is such that I believe that that
9 misconduct takes the claims outside of the statutory
10 limitations.
11 Q. And we will certainly get into that in more
12 detail, but generally, are those the two reasons why you
13 believe that the conduct at issue in the underlying
14 claims in this matter are outside the punitive damages
15 limitations?
16 A. Generally, yes. When we are talking about
17 punitive damages limitations right now, we are simply
18 focusing on statutory limitations.
19 Q. Yes, sir.
20 Did you have any involvement with the punitive
21 damages tort reform that was implemented in the late
22 1990s?
23 A. I am not sure what it is you are asking me.
24 If you are asking whether I had any involvement in
25 formulating the law, the answer to that question is I
OUELLETTE & MAUI DIN COURT REPORTERS,INC.
EFTA01130214
Page 20
1 did not.
2 Q. Who did? To your knowledge, who did formulate
3 the law?
4 A. The Florida Legislature.
5 Q. Do you have any idea who wrote the law?
6 A. I don't know the names of any of the
7 draftsmen, and I would be surprised if the end result
8 were not the product of input from multiple sources.
9 Q. Do you have any personal knowledge of that?
10 A. I don't, no, at least none that I recall.
11 There may have been some point in time when I had
12 occasion to attempt to review the legislative history,
13 but I don't remember that.
14 Q. Would the draftsmen of the punitive damages
15 statute be the best resource in terms of trying to
16 determine the intent behind the statutes?
17 A. Not necessarily, no.
18 Q. Who would be?
19 A. The Florida Supreme Court ultimately.
20 Q. And the Supreme Court looks to legislative
21 history at times to determine the intent of the statute;
22 does it not?
23 A. If it is necessary to go beyond the plain
24 meaning of the language of the statute, that is a
25 consideration that the Court might view. I don't -- I
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130215
Pagc 21
1 don't know that that would be necessary under the
2 circumstances of this statute and it certainly does not
3 appear to have been necessary up to this point in time.
4 Q. But you are not going to offer any opinions in
5 this matter on the nature and the intent of the statute
6 beyond the statutory language. Correct?
7 A. That is correct.
8 Q. And you have no personal knowledge of the
9 nature and intent of the enactment of the statute.
10 Correct?
11 A. I do not have any personal knowledge regarding
12 the drafting process nor the deliberative process of the
13 Legislature, nor do I think that either of those matters
14 is relevant.
15 Q. Do you know what groups were involved in the
16 lobbying effort for the tort reform effort?
17 A. I can make reasoned assumptions in that
18 regard, but I don't have any direct knowledge.
19 Q. In addition to the CLE courses you have taken
20 and taught on punitive damages, you also said that you
21 have done a good bit of studies conducted for punitive
22 damage purposes. Is that correct, or you have
23 researched punitive damages?
24 A. I have, yes.
25 Q. Can you please describe those research efforts
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130216
Pagc 22
1 over the years?
2 A. I have read case law. I have read treatises.
3 I have read articles in professional journals. That's
4 what comes to mind immediately.
5 Q. Is there any treatise out there that you have
6 read that you believe to be the most authoritative
7 treatise on the status of damages in the State of
8 Florida?
9 A. There is no treatise that I would accept as
10 generally authoritative on all issues with regard to
11 punitive damages.
12 Q. Is there any treatises that you would accept
13 as authoritative on some of the issues with respect to
14 punitive damages?
15 A. Well, that would depend upon a particular
16 issue and my review of the way in which the treatise
17 treats that issue. So, I can't answer that broadly.
18 Q. Are there any issues in this matter that you
19 intend to opine upon that you believe a certain treatise
20 would be authoritative?
21 A. I have not expressly reviewed any treatise for
22 purposes of formulating my opinions in this matter and
23 ascertaining whether those opinions conform with that
24 treatise so I can't answer that question.
25 What I will tell you is that I have assembled
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130217
Page'3
1 over the years some fairly extensive research materials
2 with regard to punitive damages. They certainly don't
3 include everything that I have reviewed, but it has been
4 my standard operating procedure as a trial lawyer to
5 preserve copies of materials that I think may be of some
6 significance with regard to a matter that I am currently
7 involved in or that I might reasonably anticipate would
8 become relevant to future matters, and I have kept those
9 research files and produced them for you today.
10 I selected from those files the punitive
11 damage files that I thought might be most relevant to
12 the inquiry that is being conducted.
13 Q. Thank you. So you keep a punitive damage --
14 A. I am not sure once you see them you are going
15 to want to say thank you, but I have them here.
16 Q. We appreciate it. How many times ---
17 A. Nor do I think you are going to appreciate it
18 when you get a chance to look at them, but they are
19 here.
20 Q. Thank you.
21 How many times have you testified as an expert
22 on punitive damages?
23 A. I don't have a recollection of ever having
24 served as a punitive damage expert before today.
25 Q. Have you ever been ---
OUELLETTE & MAULDIN COURT REPORTERS,INC.
EFTA01130218
Pagc 24
1 A. I am a virgin.
2 Q. Have you ever -- I will move on.
3 Have you ever been asked to serve as a
4 punitive damages expert before today?
S A. I have not, no.
6 Q. Have you ever heard of a punitive damages
7 expert before today?
8 A. Certainly not in the context of someone
9 testifying about the value of a punitive damage claim
10 but there are -- there are certainly a lot of folks out
11 there who have training and experience that formulate
12 opinions with regard to the punitive damage value of
13 cases in the ordinary course of their litigation
14 practice.
15 Q. But you have never heard -- how long, sir,
16 have you been litigating cases?
17 A. Since 1972.
18 Q. Since 1972, have you ever heard of another
19 person offering an opinion as to the value of a punitive
20 damages claim?
21 A. Many times, yes.
22 Q. And --
23 A. As a routine matter.
24 Q. Testifying in court?
25 A. No, sir. No. That wasn't the question.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130219
Pagc 25
1 That's not how I understood your question.
2 Q. I'm sorry. Then let me repeat or rephrase my
3 question.
4 Since 1972, have you ever heard or seen
5 someone testify as an expert as to the value of a
6 punitive damages claim?
7 A. You know, as you are asking that question, I
8 am thinking back to one occasion where I believe that,
9 in fact, did occur in a case that I personally
10 litigated.
11 Q. Can you tell me about that case and the
12 circumstances of that testimony?
13 A. Yes. The case was a claim against Bankers
14 Multiple Line Insurance Company. The full style of the
15 case was Farish versus Bankers Multiple Line. It was a
16 tortious interference claim against John D. MacArthur
17 and Bankers Multiple, which was a liability insurer that
18 was owned by MacArthur.
19 Joseph Farish was a trial lawyer who had been
20 hired by the widow of a young man who was walking down
21 the street when a truck came by carrying concrete
22 culverts. The truckload was not properly secured. A
23 culvert fell off the truck and crushed him as he was
24 walking down the street. The truck was owned by a
25 MacArthur Company and insured by Bankers Multiple Line
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130220
Pagc 26
1 Insurance Company.
2 The widow was an employee of John D. MacArthur
3 at a hotel that MacArthur also owned called The
4 Colonnades, and when MacArthur found out about the
5 widow's claim against his company and his insurance
6 company, he befriended the widow and convinced her to
7 terminate the services of MacArthur and to retain the
8 services of a young woman who had virtually no
9 litigation experience whatsoever who proceeded then to
10 settle the widow's claim very cheaply.
11 I represented Mr. Farish in a tortious
12 interference claim, and one of the issues was the value
13 of the underlying case. And there was expert witness
14 testimony that was given in that case about the value of
15 the claim absent the tortious interference.
16 I am blanking on the name of the trial lawyer
17 or trial lawyers who gave that testimony. That was
18 probably 25 years ago.
19 Q. So you did not present such testimony?
20 A. I'm surprised myself by remembering how much I
21 remembered about that.
22 Q. You did not present such testimony?
23 A. I did not present the testimony, no.
24 Q. In all your years of trying cases, have you
25 ever retained an expert to opine on the value of
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130221
Page 27
1 punitive damage claims that you or your client was
2 asserting?
3 A. Only the circumstances that I just described,
4 and -- well, that's the best answer I can give at this
5 time.
6 Q. Other than the research and studies that you
7 have previously described, have you performed any other
8 type of research during your career that supports your
9 purported expertise?
10 A. The process of evaluating punitive damages
11 claims is a process that goes on on a very frequent
12 basis in the course of my practice. So, to that extent,
13 the answer to your question is certainly yes.
14 Q. So you are saying you evaluate the punitive
15 claims of your own cases?
16 A. And sometimes -- well, often the cases of
17 others in my law firm and occasionally the cases of
18 lawyers outside my law firm who seek my opinion or my
19 firm's opinions with regard to the value of their cases.
20 Q. So, other than evaluating the claims that you
21 just described, your own cases, others in the firm,
22 other lawyers and so forth, have you done any other
23 research during your career that supports your purported
24 expertise?
25 A. The study that I have described to you
OUELLETTE & MA LDIN COURT REPORTERS, INC.
EFTA01130222
Page 28
1 earlier.
2 Q. Other than what we have talked about here
3 today?
4 A. I can't think of anything else that would
5 directly be relevant. Something else may come to mind.
6 If it does, I will let you know. That's all I can think
7 of right now.
8 Q. Okay. You referred to the process of
9 evaluating a punitive damages claim.
10 A. Yes, sir.
11 Q. Is that a process that you developed or was
12 that developed by some other punitive damages expert?
13 A. It is a process that has developed over the
14 course of my personal practice. That is, I haven't
15 taken somebody else's evaluative process and adopted
16 that as my own.
17 Q. And is your process an accepted process in the
18 legal industry for evaluating the value of punitive
19 damages claims?
20 A. I think the answer to that question is yes.
21 Q. Okay. And how do you know that it's -- would
22 you say it's widely accepted in the legal industry as a
23 process for evaluating the value of punitive damages
24 claims?
25 A. Yes.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130223
Page 29
1 Q. Has your method been published?
2 A. It has been.
3 Q. Where has this been published?
4 A. It has been published in court opinions of
5 which I am aware. It has been published in legal
6 treatises of which I am aware, and it has been published
7 in the CLE materials that I, myself, have written in
8 connection with lectures in this area that I have given.
9 Q. Okay. So, there is a court opinion out there
10 that discusses your internal process for evaluating the
11 value of punitive damages claims?
12 A. There is a court opinion out there that
13 addresses the issue of how punitive damages should be
14 evaluated, yes.
15 Q. And let's make sure we are talking, using the
16 same words here. How a punitive damages claim should be
17 evaluated versus how you -- how one values a purported
18 punitive damages claim. Are we talking about the same
19 thing?
20 A. That's a distinction that I don't understand.
21 Maybe I can be helpful to you here so we don't spend a
22 lot of time mis-communicating.
23 Q. That would be great.
24 A. There are authorities that identify
25 aggravating and mitigating circumstances that are
OUELLETTE & MAULDIN COURT REPORTERS,INC.
EFTA01130224
Page 30
1 appropriately taken into consideration in assessing the
2 amount of punitive damages necessary to serve the dual
3 purpose of punitive damages recognized in the State of
4 Florida, punishment and deterrence. The case that most
5 specifically addresses those factors is the
6 Johns-Manville case, which is included in the materials
7 that have been provided to you.
8 Q. Just so we are clear, when we are talking
9 about the publication of your process to evaluate
10 punitive damages, do these cases say this is how Jack
11 Scarola does it and we think that that's the proper way
12 to do it, or do these cases discuss different factors
13 that a court should consider in evaluating punitive
14 damages and you have adopted parts of that in your
15 process?
16 A. There is no published opinion that attributes
17 this process to me. There are published opinions that
18 identify appropriate factors to be taken into
19 consideration by both judges and juries in determining
20 the appropriate amount of punitive damages necessary to
21 serve the dual purpose of punishment and deterrence.
22 Q. Are there any publications, other than the
23 court opinions, that discuss Jack Scarola's process,
24 your individual process that you have utilized in this
25 matter to evaluate or to place a value on the potential
OUELLETTE & MAUI DIN COURT REPORTERS,INC.
EFTA01130225
Pagc 31
1 punitive damages claims in the underlying cases?
2 A. Except for my own materials, which obviously
3 include my name, I am not aware and would be very
4 surprised to find any case or treatise or other
5 publication that attributes the identification of
6 aggravating and mitigating circumstances to Jack
7 Scarola. This is not something that I authored, except
8 to the extent that it's incorporated in CLE outlines.
9 It is a recognition of the appropriateness of
10 specifically identified factors in both cases and
11 treatises to asses the appropriate amount of punitive
12 damages in order to serve the dual function of
13 punishment and deterrence.
14 Q. Punishment and deterrence, are those the
15 purposes of punitive damages under Florida law?
16 A. Yes, sir.
17 Q. Are punitive damages under Florida law meant
18 to compensate a plaintiff?
19 A. They are not, except to a limited extent that
20 is recognized in the case law, and that is that there is
21 a recognition in the case law that the plaintiff who
22 undertakes the prosecution of a punitive damage claim is
23 serving a function in effect as a public prosecutor to
24 preserve the integrity of the judicial system and to
25 preserve appropriate standards within, in this context,
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130226
Page 32
1 the business community. So, to motivate individuals to
2 undertake the difficult task of prosecuting a punitive
3 damage claim, one of the factors that is taken into
4 consideration are the costs involved in prosecuting that
5 claim.
6 Q. And what case ---
7 A. So punitive damages help to compensate the
8 plaintiff for undertaking that broader societal purpose.
9 Q. To recoup the costs incurred in protecting
10 society's or the state's interest in pursuing punitive
11 damages?
12 A. Yes, sir.
13 Q. And what case do you believe best describes
14 that function?
15 A. Well, I know it's described in more than one
16 case, but the one that comes to mind immediately is
17 Johns-Manville.
18 Q. What is your process for placing a value on
19 potential punitive damages claims?
20 A. It is to review the evidence in the light of
21 recognized aggravating and mitigating circumstances, to
22 assess the way in which those factors impact upon the
23 intended purpose of punitive damages to punish the
24 wrongdoer and to deter others similarly situated from
25 engaging in the same kind of wrongdoing, to review any
OUELLETTE & MAUI DIN COURT REPORTERS,INC.
EFTA01130227
v Pagc 33
1 statutory limitations that might apply and to consider
2 any constitutional limitations that might apply in
3 arriving at an opinion as to what I believe the range of
4 punitive damage value of a case is likely to be.
5 I would also take into consideration the
6 extent to which the same or similar circumstances have
7 already been assessed by an independent finder of fact.
8 Q. Let me make sure I got all of this down. It
9 seems like there is several different factors. First,
10 the evidence with respect to the claims at issue. You
11 would review that. You would review any statutory
12 limitations.
13 A. May I interrupt for just a moment?
14 Q. Yes, sir.
15 A. Because the evidence I am reviewing is
16 particularly that evidence that relates to the
17 aggravating and mitigating circumstances with respect to
18 punitive damages. I would not necessarily find it
19 necessary to review all of the evidence with respect to
20 a given matter and have not undertaken to attempt to
21 review all of the evidence with regard to this case.
22 Q. Would you review any of the evidence to
23 ascertain the viability of the underlying claims?
24 A. Certainly to some extent, yes, and I need in
25 circumstances such as this to make some assumptions with
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130228
Page 34
1 regard to the viability of the underlying case and have
2 done so here. Obviously, if this is were my own case, I
3 would be assessing all of the evidence with regard to
4 the viability of the underlying case.
5 Q. You said you had made certain assumptions in
6 this matter concerning the viability of the underlying
7 claims. Correct?
8 A. That is correct.
9 Q. What assumptions have you made?
10 A. That the underlying claims are accurately
11 described in the complaints that I have reviewed, that
12 they are accurately described in court orders that I
13 have reviewed, that they are accurately described in
14 pleadings and memoranda that I have reviewed, and to a
15 limited extent that they have been accurately described
16 in verbal communications that I have had with both
17 Mr. Moskowitz and Mr. Scherer.
18 Q. So, for your analysis of the viability of the
19 underlying claims in this matter, are you accepting all
20 of plaintiffs' allegations to be true?
21 A. Yes. I have accepted the allegations in the
22 complaint to be true to the extent that any particular
23 allegation was or is shown not to be accurate that may
24 or may not affect my opinion, and that's something that
25 I would need to view in the context of the overall case.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130229
Pagc 35
1 Q. And are you accepting all of the
2 representations from Mr. Scherer and Mr. Moskowitz as
3 true with respect to the underlying facts?
4 A. They have been very limited, bu
DataSet-10
Unknown
2 pages
IN THE CIRCUIT COURT FOR THE
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
FILE NO. 502008CP003626XXXXMB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
CROSS NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that plaintiff, E.W., will take the video deposition of:
NAME DATE AND PLACE OF TAKING DEPOSITON
TIME
Story Cowles May 12, 2010 US Legal Support
South Olive Avenue @ 10:00 AM 444 West Railroad Avenue
#201S Suite 300
West Palm Beach, FL West Palm Beach, FL 33401
(561) 835-0220
upon oral examination before US Legal Support, Notary Public, or any other notary public
or officer authorized by law to take depositions in the State of Florida. The oral
examination will continue from day to day until completed. The depositions are being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the Rules of Court.
1
EFTA00612019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
U.S. Mail and email on May , 2009 to: Robert D. Critton, Jr., Esq., Burman, Critton, et
al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401; Jay Howell, Esq., Jay
Howell & Assoc., 644 Cesery Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan
Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West
Palm Beach, FL 33401.
Farmer, Jaffe, Weissing,
Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954) 524-2820
(954) 524-2822 fax
brad@pathtojustice.com
By:
BRADLEY J. EDWARDS
Florida Bar No.: 542075
2
EFTA00612020
DataSet-10
Unknown
1 pages
Epstein: July, 2013 billing
Date Time Description
7/1/2013 2.50 Review Edwards' cases on Broward County Clerk of
Court website; print dockets
7/2/2013 0.75(-.5) Receive e-mail from THC regarding Scarola's
deposition; Make phone calls to find the court reporter
who was taking the deposition; Order
7/2/2013 1.25 Review Edwards' cases on Palm Beach County Clerk of
Court website; print cases
7/3/2013 2.25 Review Edwards' dockets on Miami-Dade County Clerk
of Court website; print cases
7/9/2013 1.00 Set up spreadsheet for recording Edwards' time spent
working on various cases; start to go through cases and
record actions taken by Edwards in an effort to track
his time during the period that the suit has been
pending
7/10/2013 1.00 Continue working on the spreadsheet and going
through the dockets
7/10/2013 2.25 (-.50) Mark up punitive damages interrogatories responses to
remove all but Fifth Amendment objections; finalize;
serve; Notice of Filing Interrogatories; file same; search
"Lilly's disk" for Motion to Compel
7/19/2013 1.50 Research and draft Motion for Bifurcation
7/22/2013 1.75 Draft fact section of Motion for Bifurcation; insert law
into Motion
7/24/2013 2.00 (-.5) Continue drafting and editing Motion for Bifurcation;
research same; review old Motions for fact section
7/25/2013 0.25 Edit Motion for Bifurcation
Total: 7 Hours at 8 hours at reduced rate of $50.00 per hour for Edwards
$150.00 case time spreadsheet = 400.00
per hour
(as edited TOTAL DUE: 1450.00
by THC in
red- red
means not
charged)=
1050.00
Total: 8.50 + 7/2 = 12
EFTA01102415
DataSet-10
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Mark Epstein on Monday, September 21, 2009, at 11:00 a.m., at:
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this //4'day of August, 2009 to all those on the
attached Service List.
EFTA00738466
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel: (954) 522-3456
Fax: (954) 527-8663
Email: bedwards rra-law.com
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reporters
EFTA00738467
DataSet-10
Unknown
1 pages
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY FLORIDA
JANE DOE, by and through JANE DOE'S Case No: 50 2008 CA 006596 XXXX MB AB
MOTHER, as parent and natural guardian
Plaintiff,
vs.
JEFFREY EPSTEIN
an
Defendant.
PLAINTIFF'S NOTICE OF TAKING DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
Jeffrey Epstein December 2, 2008 Leopold-Kuvin, PA, 2925
do Critton 9:30 AM
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted wider the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed this LY
day of November, 2008 to: ack A.
Goldber , E •.,
Bruce E. Reinhart, Esq., B
Michael R. Tein, Esq.,
osh, •., Jason A. McGrath, , McIntosh, Sawran, Peitz & Cartaya,
Robert Critton, Esq.,
LEOPOLD—KUYIN, P.A.
By:
P C , ESQ.
Florida Bar No: 089737
09112/2019 Agency to Agency Requet: 19-411
CONFi a
[5 8ENTIAL
SDNY_GM_00330503
EFTA_00203229
EFTA02728974
DataSet-10
Unknown
1 pages
rkB-01-2008 11:09 AM MYEr-- 30825a - 89 P.01
IN THE eiReurr COURT OF THE FIFTEENTH':
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO. 2006CF009454AXX
STATE OF FLORIDA
SUBPOENA FOR DEPOSITION
vs.
JEFFREY EPSTEIN,
Defendant.
TO:
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on the 4th floor (Rooms 4.2004-4.2010), of the Palm Beach County
Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on February 6. 2008 at
9:30 a.m, for the taking of your deposition In this action. If you fall to appear, you may be
in contempt of court.
You are subpoenaed to appear by the following attorneys and unless excused from
this subpoena by these attorneys or the Court, you shall respond to this subpoena as
directed.
WITNESS my hand and seal of saki Court on this 2901 day of January, 2008.
Ja oldberger, ESQ.
Fo he Court
2 Australian Avenue South, Suite 1400
est Palm Beach, Florida 33401
(561) 659-8300
09/1212019 Agency to Agency Requet 19-411
CONFIDENTIAL
a
SDNY_GM_00330074
EFTA 0020280()
EFTA02728722
DataSet-10
Unknown
5 pages
IN THE CIRCUIT COURT OF THE 15th
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO: 502008CA028051XXXXMB AB
L.M.
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
SECOND RE-NOTICE OF VIDEO DEPOSITION OF JEFFREY EPSTEIN
(CHANGE OF TIME PER DEFENDANTS REQUEST?
PLEASE TAKE NOTICE that the attorney for the plaintiff in the above-
styled cause will take the video deposition of Jeffrey Epstein on February 17,
2010 at 11:00 a.m. for the purposes of discovery at the following location:
Said deposition will be taken before US Legal Support Reporting Agency,
a Notary Public or any officer authorized to administer oaths by the laws of the
State of Florida, and a person who is neither a relative, nor employee, nor
attorney, nor counsel of any of the parties and who is neither a relative nor
employee of such attorney or counsel, and who is not financially interested in the
action.
Said deposition will be taken pursuant to Florida Rules of Civil Procedure
in such cases provided. Said oral examination will continue from hour to hour
and from day to day until completed.
EFTA00723904
CERTICATE OF SERVICE
I HEREBY CERTIFY that the original of the above and a copy of the
foregoing has been on February \ 0 , 2010 via U.S. Mail and email transmittal
to all those on the attached service list
Farmer, Jaffe, Weissing,
Edwards, Fistos & Lehrman, P.L.
•
By:
BRADLEY J. EDWARDS
Florida Bar No.: 542075
cc: US Legal (via email)
SERVICE LIST
Robert D. Critton, Jr.
BURMAN CRITTON et al.
Jay Howell, Esq.
Ja Howell & Assoc.
Jack Alan Goldberger, Esq.
oldberoer et al.
EFTA00723905
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE, CASE NO. 08-CV-80893-CIV-MARFtNJOHNSON
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.
Defendant.
Related Cases:
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE that plaintiff, Jane Doe, will take the video deposition by
oral examination, of the persons named below, at the time, on the date, at the hour of
the place indicated:
NAME DATE AND PLACE OF TAKING DEPOSITON
TIME
March 24, 2010 Prose Court Re. •rti .
c/o Bruce Reinhart 10:00 AM
Bru e E. Reinhart P.A.
upon oral examination before Prose Court Reporting, Notary Public, or any other notary
public or officer authorized by law to take depositions In the State of Florida. The oral
EFTA00723906
CASE NO: 08-CV-80119-MARRAMOHNSON
examination will continue from day to day until completed. The depositions are being
taken for the purpose of discovery, for use at trial, or for such other purposes as are
permitted under the Rules of Court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing was served by e-mail on February
12, 2010 to: See attached service list.
Bradley J. Edwards
Farmer, Jaffe, WeissIng,
II le h n, PL
f
By: ---cra-cc, C1C2
BRADLEY J. EDWARDS
Florida Bar No.: 542075
2
EFTA00723907
CASE NO: 08-CV-80119-MARRAJJOHNSON
SERVICE LIST
Jane Doe v. Jeffrey Epstein
United States District Court - Southern District of Florida
Jack Alan Goldber er Esq.
Robert D. Critton Esq.
Isidro Manual Garcia
Jack Patrick Hill
th rin n zell
ul assell
Richard Horace Willits
lb&
Adam D• Ho itz
EFTA00723908
DataSet-10
Unknown
1 pages
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
B.B Case No: 502008CA037319)OOOCMB AB
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
TAKING DEPOSITION
PLAINTIFF'S RE-NOTICE OFsmith
(Coordinated with Mr. Gold 's attornev's office)
RNEY WILL TAKE THE DEPOSITION OF:
PLEASE TAKE NOTICE THAT THE UNDERSIGNED' ATTO
DATE AND TIME: LOCATION:
NAME:
April 19, 2010 Prose Court Reporting, 250 S.
Charles Gerald Goldsmith
9:30 AM Australian Avenue, Suite
1500, West Palm Beach, FL
33401
by law to take depositions in
upon an oral examination before a Notary Public or officer authorized
to day until completed. The
the State of Florida. The oral examination will continue from day
trial or are being taken for such
depositions are being taken for purposes of discovery, for use at
other purposes as are permitted under the Rules of the Court.
true and correct copy of this Notice was mailed this ZO_
WE HEREBY CERTIFY that aerger,
day of February, 2010 to: Jack A. GoldbEsq., 250 Australian Avenue, Suite 1400, West Palm
Avenue South, Suite 1400, West Palm
Beach, FL 33401; Bruce B. Reinhart Esq., 250 Australian
Banyon Boulevard, Suite 400, West
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303
PA, 501 s. Flagler Drive, Suite
Palm Beach, FL 33401; Jeffiey Fisher, Esq., Fisher & Bendeck,
450, West Palm Beach, FL 33401.
LEOPOLD-.KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
Florida Bar No: 089737
EFTA00606703
DataSet-10
Unknown
6 pages
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
FORT LAUDERDALE DIVISION
www.flsb.uscourts.gov
INRE: CASE NO.: 09-34791-RBR
ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER II
Debtor.
RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
TO: All counsel on the attached Counsel List
PLEASE TAKE NOTICE that the undersigned attorneys will take video deposition of:
NAME AND ADDRESS DATE. AND TIME LOCATION
Corporate Representative August 21, 2018
Carlton Fields
of Fowler White Burnett, 1:00 p.m. CityPlace Tower
P.A. (to be designed by
525 Okeechobee Boulevard
Fowler White)
Suite 1200
West Pal B ach, FL 33401-5350
VIDEOGRAPHER: Above & Beyond Reprographics, Inc.
upon oral examination before Palm Beach Reporting, Inc., a Notary Public; or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the
applicable Statutes or Rules.
*DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF
THE DEPOSITION THE FOLLOWING:
EFTA00802378
In Re: Rothstein Rosenfcldt Adler, P.A.
Case No. 09-3479I-RBR
ReNotice of Taking Video
Deposition Page2
pucFS TECUM*
1. All communications and all records relating to the chain of custody of the subject disk itself and/or
relating to the chain of custody of information derived from documents or data contained on the
subject disk.
2. All communications and all records exchanged by or on behalf of Fowler White and Jeffrey Epstein
and/or any attorney or representative of Jeffrey Epstein, including but not limited to Link &
Rockenbach, P.A., from November I, 2010 to February I, 2018, which relate to the subject disk itself
or any information derived from documents or data contained on the subject disk.
3. All communications and all records exchanged by or on behalf of Fowler White and Jeffrey Epstein
and/or any attorney or representative of Jeffrey Epstein, including but not limited to Link &
Rockenbach, P.A., from February 1, 2018 to the date of your deposition, which relate to the subject
disk itself or any information derived from documents or data contained on the subject disk.
4. All communications and all records exchanged by or on behalf of Fowler White and Jeffrey Epstein
and/or any attorney or representative of Jeffrey Epstein, including but not limited to Link &
Rockenbach, P.A., from February 25, 2018 to March 8, 2018, which relate to the subject disk itself or
any information derived from documents or data contained on the subject disk.
•"Documents" shall include, but not be limited to all non-identical copies of writings,
drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data
compilations from which information can be obtained, translated, if necessary, by the party to
whom the request is directed through detection devices into reasonably usable form. "Documents"
also include all electronic data as well as application metadata and system metadata. All
inventories and rosters of your information technology (IT) systems--e.g., hardware, software and
data, including but not limited to network drawings, lists of computing devices (servers, PCs,
laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
and security tools and protocols.
EFTA00802379
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
ReNotice of Taking Video
Deposition Page3
I HEREBY CERTIFY that a true and correct copy ofthe foregoing was sent via E-
Serve to all Counsel on the attached list, this 2.0 day of July, 2018.
DJ VIU P VITALE JR.
Florida Bar No.: 115
Primary E-Mail: ■
Searcy Denney Scarola Barnhart & Shipley,
2139 Palm Beach Lakes Boulevard
West Palm Beach da 33409
Phone:
Fax:
Attorneys for Bradley J. Edwards
cc: Palm Beach Reporting, Inc. (court reporter)
Above & Beyond Reprographics, Inc. (videographer)
F-TRANSCRIPT. ASCII. CD AND/OR DVD REOUESTED
EFTA00802380
Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
ReNotice of Taking Video
Deposition Page4
COUNSEL LIST
Joseph L. Ackerman, Jr., Esq.
Fowler White Burnett, P.A.
901 Phillips Point West
777 South Flagler Drive
West Pal a 33401-6170
Pho
Fax:
Attorneys oreJeffrey Epstein
Scott J. Link, Esq.
Link & Rockenbach, P.A.
1555 Palm Beach Lakes Boulevard
Suite 301
We 3401
Ph
Fax
Attorneys for Jeffrey Epstein
Jack A. Goldbe er, Esquire
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue S, Suite 1400
West Palm Beach. 33401
Pho
Fax:
Attorneys for Jeffrey Epstein
Phil Burlington, Esq.
Nichole J. Segal, Esquire
Burlington & Rockenbach, P.A.
444 W Railroad Avenue, Suite 350
West PIES401
Phone:
Attorneys for Bradley J. Edwards
EFTA00802381
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
ReNotice of Taking Video
Deposition PageS
EDWARDS POTTINGER LLC
Bradley J. Edwards FLBN 54207
Brittany N. Henderson FLBN 118247
Edwards Pottinger LLC
425 N Andrews Avenue, Suite 2
Fort Lauderdale. FL 33301
Pho
Fax:
Jay Howell
Jay Howell & Associates
Florida Bar No.: 225657
Attorney E-Mail(s):
644 Cesery Blvd. #250
Jacksonville. FL 32211
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
332 S. University St.
Salt Lake City, UT 84112
(above for address purposes only)
Attorney E-Mail:
Attorneys for L.M., E.W., and Jane Doe
Joseph lanno, Jr., Esquire
Carton Fields
CityPlace Tower
525 Okeechobee Boulevard, Suite 1200
West Palm
Telephone:
Fax:
Attorneys for Fowler White Burnett, P.A.
Isaac M. Marcushamer
Berger Singerman LLPO
1450 Brickell Avenue, Suite 1900
Miami, FL 33131
Counsel for Litigating Trustee
EFTA00802382
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
ReNotice of Taking Video
Deposition Page6
"If you are a person with a disability who needs any accommodation in
order to participate in this proceeding, you are entitled, at no cost to you,
to the provision of certain assistance. Please contact Americans with
Disabilities Act Coordinator at least 7 days before your scheduled court
appearance, or immediately upon receiving this notification if the time
before the scheduled appearance is less than 7 days; if you are hearing or
voice impaired, call 711."
"Si usted es una persona minusvalida que necesita algun acomodamiento
pan poder participar en este procedimiento, usted tiene derecho, sin
tener gastos propios, a que se le proves cierta ayuda. Tenga la
amabilidad de ponerse en contacto con Americans with Disabilities Act
Coordinator por lo menos 7 dias antes de la cita fijada para su
comparecencia en los tribunales, o inmediatamente despues de recibir
esta notificaci6n si el tiempo antes de la comparecencia que se ha
programado es menos de 7 dias; si usted tiene discapacitacion del oido o
de la voz, llame a1711."
"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe
nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen
pwovizyon pou jwen kek ed. Tanpri kontakte Americans with Disabilities
Act Coordinator nan 7 jou anvan dat ou gen randevou pou paret nan
tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon an si le
ou gen pou w paret nan tribinal la mwens ke 7 jou; si ou gen pwoblem
pou w tande oubyen pale, rele 711."
EFTA00802383
DataSet-10
Unknown
1 pages
To: Jeffrey Epsteinfleeyacation©gmail.com]
From: Story Cowles
Sent: Mon 9/14/2009 8:28:15 PM
Subject: Palm Beach sex offender Jeffrey Epstein fined for walking out of deposition
http://www.palmbeachdailynews.com/news/content/news/2009/09/14/webepstein091409.h
tml
Sent from Story's iPhone
EFTA_R1_01510126
EFTA02437329
DataSet-10
Unknown
159 pages
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
08076.08089 08/04/2009 Bradley Edwards Spencer Kuvin Transcript of Alfredo Rodriguez Joint W/P Priv.
Deposition
08311-08318 05/26/2009 Bradley Edwards Katherine Ezell WPB-Confidential-General- Joint W/P Priv.
Financial Disclosure/Discovery
08319-08324 10/16/2009 Bradley Edwards Amy Ederi WPB-General-Confidential Joint W/P Priv.
08398 09/01/2009 Bradley Edwards Kikka Claudio C.M.A. vs. Epstein, et Joint W/P Priv.
als(File#:281849)
08402 09/17/2009 Bradley Edwards Paul Cassell Report this as a parole violation Joint W/P Priv.
08415 09/16/2009 Bradley Edwards Margaret Berk Scanned document from Joint W/P Priv.
Margaret Berk
08422 08/11/2009 Bradley Edwards Katherine Ezell Subpoena directed to the Joint W/P Priv.
investigators
10060 08/03/2009 Adam Horowitz Jacquie Johnson Epstein-Depo-New York Joint W/P Priv.
10069-10074 08/04/2009 Bradley Edwards Spencer Kuvin RE:Transcript of Alfredo Joint W/P Priv.
Rodriguez Deposition
10077.10079 08/06/2009 Bradley Edwards Mercedes Estrada RE:Epstein vs. Jane Doe No.101 Joint W/P Priv.
& Epstein vs. Jane doe No. 102
10099-10102 08/27/2009 Bradley Edwards Spencer Kuvin RE: Epstein Depo Joint W/P Priv.
10192 08/11/2009 Adam Horowitz Jacquie Johnson Trump Depo moved 08/18 to Joint W/P Priv.
9/24 in NY
10194.10195 08/11/2009 Jacquie Johnson Kikka Claudio FW: Out of state subpoenas Joint W/P Priv.
10264-10266 08/09/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Letter regarding Joint W/P Priv.
Leslie Wexner
1
EFTA00602835
Privilege Log— Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
10279-10291 08/10/2009 Adam Horowitz Jacquie Johnson RE: Epstein-Notice of production Joint W/P Priv.
from non parties/depo of Jane
Doe
10372-10373 09/17/2009 Bradley Edwards Katherine Ezell RE: Leslie Wexner Joint W/P Priv.
10490-10493 09/21/2009 Bradley Edwards Amy Ederi FW: Epstein Depo Joint W/P Priv.
10592.10593 09/29/2009 Bradley Edwards Katherine Ezell RE: Leslie Wexner Joint W/P Priv.
10604.10620 10/01/2009 Bradley Edwards Katherine Ezell FW:meeting w/ atty fr wexner Joint W/P Priv.
10639-10643 10/06/2009 Bradley Edwards Stuart Mermelstein Meeting w/Leslie Wexner Joint W/P Priv.
10700-10702 10/13/2009 Adam Horowitz Jacquie Johnson Depo Joint W/P Priv.
10724-1073 10/14/2009 Adam Horowitz Jacquie Johnson Epstein-depo of Alan Dershowitz Joint W/P Priv.
10897 10/29/2009 Bradley Edwards Stuart Mermelstein Leslie Wexner Joint W/P Priv.
10992-11005 06/22/2009 Bradley Edwards Amy Ederi RE:Regular Monthly Cong. Call Joint W/P Priv.
11011-11021 06/23/2009 Bradley Edwards Katherine Ezell RE:Regular Monthly Cong. Call Joint W/P Priv.
11026-11032 07/09/2009 Bradley Edwards Spencer Kuvin RE:Epstein commissioner Joint W/P Priv.
appointees
11072.11074 07/28/2009 Bradley Edwards Katherine Ezell Possible witness from Joint W/P Priv.
Switzerland
11166-11169 06/23/2009 Katherine Ezell Bradley Edwards RE:Article:Bear Stearns Joint W/P Priv.
2
EFTA00602836
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
11240-11245 06/22/2009 Katherine Ezell Bradley Edwards Article:Bear Stearns Joint W/P Priv.
11248.11250 06/22/2009 Amy Ederi Bradley Edwards Article:Bear Stearns Joint W/P Priv.
11255-11259 06/23/2009 Katherine Ezell Bradley Edwards USAO Chose Bradley Edwards Joint W/P Priv.
conversation
11269-11281 06/30/2009 Stuart Bradley Edwards RE:Epstein Depo;possible Joint W/P Priv.
Mermelstein deponents
11316.11319 06/28/2009 Katherine Ezell Bradley Edwards Discussion about possible Joint W/P Priv.
witness from Switzerland
11332-11336 08/04/2009 Spencer Kuvin Bradley Edwards FW:Transcript of Alfrefo Joint W/P Priv.
Rodriguez Depo and Copperfeild
and Clinton's whereabouts
11340-11341 08/05/2009 Mercedes Bradley Edwards RE:Epstein vs.Jane Doe No.101 & Joint W/P Priv.
Estrada 102
11348-11358 08/06/2009 Adam Horowitz Bradley Edwards RE:Motion for protective Joint W/P Priv.
order/discussion
11430-11434 08/27/2009 Spencer Kuvin Bradley Edwards Discussion RE:Wexner Joint W/P Priv.
involvement
11443 09/17/2009 Katherine Ezell Bradley Edwards Wexner served subpoena OH Joint W/P Priv.
11541-11542 09/29/2009 Katherine Ezell Bradley Edwards RE:Leslie Wexner & Bob Joint W/P Priv.
11551-11559 10/01/2009 Spencer Kuvin Bradley Edwards RE:Meeting w.Stanely Arkin Joint W/P Priv.
11585.11586 10/14/2009 Adam Horowitz Bradley Edwards RE:Epstein;Larry Visoski Joint W/P Priv.
confirmed
11675-11676 10/29/2009 Stuart Bradley Edwards RE:Leslie Wexner attorney info Joint W/P Priv.
Mermelstein
3
EFTA00602837
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
15981-15988 08/04/2009 Spencer Kuvin Jacquie Johnson Attachment:Kellen & Trump Joint W/P Priv.
subpoena
15999.16007 08/05/2009 Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint W/P Priv.
16057-16065 08/06/2009 Mercedes Jacquie Johnson Trump and Maxwell Dep dates Joint W/P Priv.
Estrada
15918-15949 08/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo's 08/14,17,18 in Joint W/P Priv.
NY & OH
16066-16069 08/06/2009 Adam Horowitz Jacquie Johnson Maxwell,Trump, Wexner convo Joint W/P Priv.
RE:Depo dates
16095-16098 08/11/2009 Adam Horowitz Jacquie Johnson Maxwell,Trumo,Wexner Convo Joint W/P Priv.
RE:Depo dates cont..
15813.15814 10/29/2009 Stuart Bradley Edwards Wexler Lawyer's info Joint W/P Priv.
Mermelstein
15856 08/03/2009 Adam Horowitz Jacquie Johnson Epstein Depo-NY:2 Attachments Joint W/P Priv.
15866-15881 08/03/2009 Adam Horowitz Jacquie Johnson Epstein Depos 08/14,17,18 in Joint W/P Priv.
NY&OH/PDF of
Notice of Videotaped Depo
15893-15901 08/03/2009 Kikka Claudio Jacquie Johnson Depo &subpoena notice for Joint W/P Priv.
Trump
15360-15363 09/01/2009 Jacquie Johnson Mercedes Estrada RE:Alan Dershowitz;Harvard Law Joint W/P Priv.
Info
15394-15397 09/09/2009 Jacquie Johnson Katherine Ezell RE:E stein-De os of Joint W/P Priv.
&
15413.15428 09/10/2009 Adam Horowitz Jacquie Johnson RE:Esptein-Notice of Prodcution Joint W/P Priv.
from Non Parties
15434-15437 09/10/2009 Jacquie Johnson Katherine Ezell Notice Of Production from Non- Joint W/P Priv.
Parties discussion
4
EFTA00602838
Privilege Log - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
15454-15475 09/15/2009 Adam Horowitz Jacquie Johnson Critton's notice of depo;Epstein Joint W/P Priv.
notice of hearing,Mark Epstein
notice of depo
01465 07/13/2009 Katherine Ezell Bradley Edwards Epstein Joint W/P Priv.
15485-15492 09/17/2009 Jacquie Johnson Mercedes Estrada RE:Epstein Depo Joint W/P Priv.
15493.15500 09/18/2009 Jacquie Johnson Katherine Ezell RE:Deposition of Jean Luc Joint W/P Priv.
Bruhnel
15501.15555 09/18/2009 Jacquie Johnson Adam Horowitz RE:Epstein Depo Joint W/P Priv.
15556-15564 09/22/2009 Jacquie Johnson Margaret Berk Epstein Depos Joint W/P Priv.
15565.15575 09/25/2009 Jacquie Johnson Lisa Rivera FW:Deposition of Jean Luc Joint W/P Priv.
Bruhnel
15687.15688 10/01/2009 Jacquie Johnson Lisa Rivera Depo of David Hart Rogers Joint W/P Priv.
15692-15707 10/01/2009 Jacquie Johnson Katherine Ezell FW:Meeting w/Sranley Arkin Joint W/P Priv.
15708-15709 10/06/2009 Jacquie Johnson Mercedes Estrada RE:Jane Does 2-8v. Epstein-Cross Joint W/P Priv.
Nod's of Oct 6.8 depos
15033-15032 08/05/2009 Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for 8/17 Joint W/P Priv.
15087.15093 08/06/2009 Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for 8/17 Joint W/P Priv.
15094-15100 08/06/2009 Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv.
15109-15112 08/10/2009 Jacquie Johnson Adam Horowitz RE:Epstein Depositions for Joint W/P Priv.
8/14,17,18 in NY & OH
5
EFTA00602839
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
15122-15125 08/11/2009 Jacquie Johnson Kikka Claudio RE: Ms. Maxwell Depo Joint W/P Priv.
rescheduled
15142-15158 08/11/2209 Bradley Edwards Kikka Claudio FW:out of state subpoenas Joint W/P Priv.
15166-15170 08/11/2009 Jacquie Johnson Kikka Claudio RE:out of state subpoenas Joint W/P Priv.
15171-15172 08/11/2009 Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv.
15178-15182 08/12/2009 Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv.
15306.15355 08/25/2009 Jacquie Johnson Kikka Claudio FW:Epstein Depo Notices & Subs Joint W/P Priv.
14951-14952 08/03/2009 Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv.
14954-14972 09/16/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Depo of Mark Epstein Joint W/P Priv.
on 9/21 in NY will take place as
scheduled
14979-14981 08/03/2009 Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv.
14983-15015 08/04/2009 Jacquie Johnson Adam Horowitz RE:Epstein Depositions 8/14.17, Joint W/P Priv.
&18 in NY & 01-I
16501-16519 09/15/2009 Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv.
16520-16547 09/09/2009 Spencer Kuvin Jacquie Johnson RE:Epstein-Deposition of Jane Joint W/P Priv.
Doe-9/30/2009
16355-16384 08/24/2009 Adam Horowitz Jacquie Johnson Epstein Depo Notices and Subs Joint W/P Priv.
16554.16568 09/16/2009 Kikka Claudio Jacquie Johnson RE:Epstein Depo Joint W/P Priv.
6
EFTA00602840
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
16574.16577 09/17/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv.
16396-16398 09/01/2009 Margaret Estrada Jacquie Johnson Alan Dershowitz Joint W/P Priv.
16578-16581 09/17/2009 Katherine Ezell Jacquie Johnson RE:Depo Joint W/P Priv.
16582-16585 09/18/2009 Adam Horowitz Jacquie Johnson RE:Deposition of Jean Luc Joint W/P Priv.
Bruhnel
16585-16611 09/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv.
16612-16439 09/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Depo of Mark Epstein Joint W/P Priv.
16440 08/18/2009 Spencer Kuvin Jacquie Johnson RE:Epstein Sub to Bear Steam Joint W/P Priv.
16740-16753 09/22/2009 Margaret Berk Jacquie Johnson RE:Epstein Depos Joint W/P Priv.
16443-16452 09/09/2009 Katherine Ezell Jacquie Johnson RE:Epstein-Depos of Joint W/P Priv.
&
16777-16786 09/30/2009 Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv.
16793-16794 10/01/2009 Lisa Rivera Jacquie Johnson RE:Depo of David Hart Rogers Joint W/P Priv.
16462-16477 09/10/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
16802-16823 10/02/2009 Margaret Berk Jacquie Johnson RE:Epstein depos Joint W/P Priv.
16483-16486 09/10/2009 Katherine Ezell Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
7
EFTA00602841
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
16874-16880 10/13/2009 Adam Horowitz Jacquie Johnson Depo Joint W/P Priv.
16904-16905 10/14/2009 Spencer Kuvin Jacquie Johnson RE:Epstein Joint W/P Priv.
16945 10/26/2009 Kikka Claudio Jacquie Johnson RE:Epstein depos on 10/28 Joint W/P Priv.
17033-17034 10/26/2009 Kikka Claudio Jacquie Johnson RE:Epstein depos on 10/28 Joint W/P Priv.
02065-02068 06/08/2009 Bradley Edwards Mercedes Estrada FW:Epstein-Confirming AT&T Joint W/P Priv.
Dial Telephone Conference for
Mon 6/8/09 at 2:00 p.m.
02070 09/02/2009 Jacquie Johnson Spencer Kuvin FW:Epstein-De I os of Joint W/P Priv.
&
02071 08/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns Joint W/P Priv.
02072-02078 09/04/2009 Jacquie Johnson Spencer Kuvin FW:Epstein-De • os of Joint W/P Priv.
&
03466-03468 05/14/2009 Spencer Kuvin Bradley Edwards RE:Actvity in Case 9:08-cv- Joint W/P Priv.
80893-KAM Doe v. Epstein Order
on Motion to Stay
02301.02302 09/09/2009 Paul Cassel Bradley Edwards FW:Epstein Joint W/P Priv.
03122-03123 06/10/2009 Adam Horowitz Bradley Edwards FW: Motion to Dismiss Joint W/P Priv.
02805-02806 05/26/2009 Susan Stirling Katherine Ezell RE:WPB-Confidential-Genereal- Joint W/P Priv.
Financial Disclosure/Discovery
02670-02671 10/21/2009 Bradley Edwards Spencer Kuvin FW:Subpoena Info Joint W/P Priv.
02517-02519 10/02/2009 Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv.
8
EFTA00602842
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
02614.02617 08/05/2009 Bradley Edwards Kikka Claudio FW:Proposal Request Joint W/P Priv.
15702.15704 10/02/2009 Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv.
15581-15585 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv.
15431.15433 09/10/2009 Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
15797-15798 10/14/2009 Spencer Kuvin Bradley Edwards RE:Epstein Joint W/P Priv.
11560-11562 10/02/2009 Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv.
Johnson
11444-11448 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv.
05823 09/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv.
05832 09/08/2009 Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv.
05838 09/08/2009 Jacquie Johnson Jack Hill RE:Epstein Joint W/P Priv.
05847 09/09/2009 Jacquie Johnson Katherine Ezell RE:Epstein Joint W/P Priv.
05859 07/23/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05863-05864 07/23/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05886-05887 07/24/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
9
EFTA00602843
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05902.05903 07/28/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05906-05907 07/28/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05912 08/27/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05928-05930 07/28/2009 Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv.
05933-05934 09/18/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05936 09/18/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05938 09/18/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv.
05940-05941 09/18/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05951 05/29/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05957-05960 09/09/2009 Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv.
05970-05971 10/21/2009 Jacquie Johnson Margaret Berk RE:Epstein Joint W/P Priv.
05982-05983 10/28/2009 Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv.
05993-05994 09/09/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv.
05997 08/06/2009 Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv.
10
EFTA00602844
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
01029 10/08/2009 Bradley Edwards Carolyn Edwards Brian Ryalls Joint W/P Priv.
07707 09/03/2009 BradleyEdwards Kikka Claudio RE:Regarding:C.M.A. vs. Epstein. Joint W/P Priv.
Et al.(File# 281849)
07708.07709 06/22/2009 Bradley Edwards Amy Ederi RE:Regular Monthly Cong. Call Joint W/P Priv.
07734 07/24/2009 Bradley Edwards RE:Release Joint W/P Priv.
07218.07219 10/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv.
06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv.
06876.06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv.
06891-06897 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv.
06901 09/11/2009 Bradley Edwards Mercedes Estrada Re:Jane Doe No. 101 & Jane Doe Joint W/P Priv.
No. 102 vs. Epstein-Cross Notice
Of Depos
06902 09/15/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe No.101 & Jane Doe Joint W/P Priv.
NO.102 vs. Epstein
06903 09/04/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe No.101 & Jane Doe Joint W/P Priv.
NO.102 vs. Epstein-Cross-Notice
of Taking Video Deposition
06806-06807 09/09/2009 Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv.
06712 10/19/2009 Bradley Edwards Kikka Claudio RE: Igor Zinoview depo Joint W/P Priv.
06713-06714 09/15/2009 Bradley Edwards Robert Josefberg RE:Epstein Joint W/P Priv.
11
EFTA00602845
Privilege Loa - Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
06720-06727 10/14/2009 Bradley Edwards Jack Hill RE: Igor Zinoview depo Joint W/P Priv.
06728 09/09/2009 Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv.
06711 09/09/2009 Kikka Claudio Bradley Edwards RE:Epstein Joint W/P Priv.
06472 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06460.06464 05/08/2009 Bradley Edwards Spencer Kuvin RE:FYI Epstein Depo Joint W/P Priv.
06455-06459 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06448-06452 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06420-06427 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
06416-06419 05/08/2009 Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv.
05925-05926 07/28/2009 Katherine Ezell Bradley Edwards FW:Epstein Joint W/P Priv.
05883-05584 07/24/2009 Katherine Ezell Bradley Edwards RE:Epstein Joint W/P Priv.
05022.05025 09/10/2010 Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv.
from Non Parties
04724-04725 05/27/2009 Bradley Edwards Katherine Ezell RE:Epstein Cases-depostions in Joint W/P Priv.
federal cases
BATES DATE TO FROM DESCRIPTION OBJECTION
06990-07002 06/11/2009 Brad Edwards Katherine W. Ezell June 10th hearing-WPB- Joint-privilege
Confidential
07003-07006 06/26/2009 Amy Ederi Brad Edwards June 25th hearing-WPB- Joint-privilege
12
EFTA00602846
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissint Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Confidential
07030 09/22/2009 Bradley J. Spencer Kuvin IM v. Epstein — defendant, Joint-privilege
Edwards Jeffrey Epstein's response to
plantiff
07090-07091 9/29/2009 Bradley J. Katherine W. Ezell Leslie Wexner Joint-privilege
Edwards
07092 10/29/2009 Stuart Bradley J. Edwards Leslie Wexner Joint-privilege
Mermelstein
07093 09/17/2009 Bradley J. Katherine W. Ezell Leslie Wexner Joint-privilege
Edwards
01484 05/21/2009 Robert C. BradleyJ. Edwards Epstein Joint-privilege
Josefsberg
01503 08/24/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01517 09/18/2009 Adam Horowitz; Bradley J. Edwards Epstein Joint-privilege
Spencer Kuvin
01514 08/26/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01515 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Joint-privilege
01477 07/21/2009 Adam Horowitz; Bradley J. Edwards Epstein Joint-privilege
Stuart
Mermelstein
01489 08/03/2009 Adam Horowitz Bradley J. Edwards Epstein Joint-privilege
07110-07112 09/25/2009 Bradley J. Spencer Kuvin LM v EPSTEIN hearing 9/22/09
Edwards
07113.07114 09/25/2009 Spencer Kuvin Bradley J. Edwards LM v EPSTEIN hearing 9/22/09 Joint-privilege
07115-07116 09/25/2009 Bradley J. Spencer Kuvin LM v EPSTEIN hearing 9/22/09 Joint-privilege
Edwards
07145-07146 09/22/2009 Adam Horowitz Bradley J. Edwards Mark Epstein Joint-privilege
07211-07213 10/01/2009 Bradley J. Spencer Kuvin Meeting with Stanley Arkin Joint-privilege
Edwards
07210 10/06/2009 Stuart Katherine W. Ezell Meeting with Leslie Wexner Joint-privilege
Mermelstein;
Robert c.
Josefsberg;
13
EFTA00602847
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Bradley J.
Edwards
07214-07215 10/01/2009 Robert C. Katherine W. Ezell Meeting with Stanley Arkin Joint-privilege
Josefsberg
07216-07217 10/02/2009 Bradley J. Katherine W. Ezell Meeting with Stanley Arkin Joint-privilege
Edwards
07220-07223 10/01/2009 Spencer Kuvin Bradley J. Edwards Meeting with Stanley Arkin Joint-privilege
07224-07225 10/02/2009 Katherine W. Bradley J. Edwards Meeting with Stanley Arkin Joint-privilege
Ezell
07226-07227 10/01/2009 Robert C. Spencer Kuvin Meeting with Stanley Arkin Joint-privilege
Josefsberg
07228-07229 10/01/2009 Bradley J. Robert C. Meeting with Stanley Arkin Joint-privilege
Edwards Josefsberg
07280-07283 08/06/2009 Adam Horowitz Bradley J. Edwards Motion for protective order Joint-privilege
07633-07634 08/06/2009 Bradley J. Kikka M. Claudio Proposal Request Joint-privilege
Edwards
07710-07733 06/23/2009 Katherine W. Bradley J. Edwards Regularly Monthly Cong. Call Joint-privilege
Ezell
07740-07746 09/18/2009 Bradley J. Adam Horowitz Report this as a parole violation Joint-privilege
Edwards
07748.07757 09/18/2009 Adam Horowitz Bradley J. Edwards Report this as a parole violation Joint-privilege
07913-07915 08/27/2009 Bradley J. Spencer Kuvin Joint-privilege
Edwards
07917.07918 08/27/2009 Spencer Kuvin Jacquie Johnson Joint-privilege
07965-07966 08/12/2009 Katherine W. Bradley J. Edwards Subpoena directed to the Joint-privilege
Ezell investigators
07977-07978 10/09/2009 Bradley J. Spencer Kuvin Subpoena Info Joint-privilege
Edwards
01716 09/15/2009 Adam Horowitz Elizabeth Villar Epstein: Forensics/Investigations Joint-privilege
INVOICE
01768 07/13/2009 Richard Willits Bradley J. Edwards Epstein Investigator Joint-privilege
01771.01772 08/06/2009 Adam Horowitz Bradley J. Edwards Epstein Investigator Joint-privilege
01931 08/11/2009 Bradley J. Lisa Rivera Alfredo Rodriguez Joint-privilege
14
EFTA00602848
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Edwards
01998-01999 09/21/2009 Adam Horowitz Margaret Berk Correct Number — Epstein Joint-privilege
Deposition
02021 05/14/2009 Bradley J. Mercedes C. Doe v. Epstein Joint-privilege
Edwards Estrada
02044 09/04/2009 Katherine W. Bradley J. Edwards E.W., Doe v. Epstein — Joint-privilege
Ezell Letter from Bob Critton
02048 09/04/2009 Robert C. Bradley J. Edwards E.W., Doe v. Epstein — Joint-privilege
Josefsberg Letter from Bob Critton
02054 05/12/2009 Spencer Kuvin Bradley J. Edwards Emailing Epstein deposition Joint-privilege
revised
02062 10/05/2009 Bradley J. Amy Ederi Epstein — Confirming AT&T Dial Joint-privilege
Edwards in Tel. Conf. for Monday,
10/5/09 at 4:00 p.m.
02087 09/17/2009 Spencer Kuvin Bradley J. Edwards Epstein- Hearing Joint-privilege
02140 08/04/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo — New York Joint-privilege
02147-02149 09/21/2009 Bradley J. Amy Eden Epstein Depo Joint-privilege
Edwards
02174 07/20/2009 Adam Horowitz Bradley J. Edwards Epstein Matter — Cross Notice of Joint-privilege
Alfredo Rodriguez Deposition
02209-02210 07/01/2009 Bert Patton William J. Berger Epstein v. State of Florida — Joint-privilege
Emergency petition for Writ of
Certiorari; Emergency motion to
review denial of stay
02215-02217 07/24/2009 Bradley J. Mercedes C. Epstein Joint-privilege
Edwards Estrada
02290 09/18/2009 Bradley J. Spencer Kuvin Epstein Joint-privilege
Edwards
02355.02356 06/10/2009 Mercedes C. Susan K. Stirling Hearing taken on 06/10/09 Joint-privilege
Estrada onmotion to unseal before Judge
Colbath
02362.02363 06/09/2009 Spencer Kuvin Katherine W. Ezell Hearing to Un-seal Joint-privilege
02374-02375 09/15/2009 Jack Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege
15
EFTA00602849
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
02420-02421 OS/08/2009 Bradley J. Mercedes C. Jane Doe II v. Epstein Joint-privilege
Edwards Estrada
02435 09/15/2009 Bradley J. Lisa Rivera Jane Does v. Epstein Joint-privilege
Edwards
02438 09/18/2009 Bradley J. Adam Horowitz Jeffrey Epstein oat W35755 Joint-privilege
Edwards
02462 09/22/09 Spencer Kuvin Bradley J. Edwards I■ v. Epstein — Defendant, Joint-privilege
Jeffrey Epstein"s Response to
Plantiff •'s Motion for
Protective Order
02476-02477 09/25/2009 Spencer Kuvin BradleyJ. Edwards LM v EPSTEIN hearing Joint-privilege
02516 10/06/2009 Bradley J. Katherine W. Ezell Meeting with Leslie Wexner Joint-privilege
Edwards
02554.02559 08/03/2009 Adam Horowitz Bradley J. Edwards NEW ASSIGNMENT — NEW Joint-privilege
ALBANY — RUSH? — Fwd: Federal
Subpoena
02584 08/11/2009 Bradley J. Kikka M. Claudio Out of state subpoenas Joint-privilege
Edwards
02618 08/04/2009 Bradley J. Kikka M. Claudio Proposal Request Joint-privilege
Edwards
02627-02628 09/18/2009 Bradley J. Adam Horowitz Report this as a parole violation Joint-privilege
Edwards
02672-02673 10/09/2009 Spencer Kuvin Bradley J. Edwards Subpoena Info Joint-privilege
02727 08/03/2009 Spencer Kuvin Bradley J. Edwards Transcript of Alfredo Rodriguez Joint-privilege
deposition
02896 06/08/2009 Bradley J. Spencer Kuvin Hearing to Un-seal Joint-privilege
Edwards
03009-03010 08/07/2009 Adam Horowitz Jacquie Johnson Motion to stay Joint-privilege
03028.03029 09/21/2009 Bradley J. Adam Horowitz Mark Epstein Joint-privilege
Edwards
03038 10/06/2009 Bradley J. Stuart Mermelstein Meeting with Leslie Wexner Joint-privilege
Edwards
03131-03132 08/06/2009 Adam Horowitz Bradley J. Edwards Epsteins assets Joint-privilege
16
EFTA00602850
Privilege Log — Dated 2-23-2011
Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
03243.03244 09/09/2009 Bradley J. Adam Horowitz EPSTEIN Joint-privilege
Edwards
03397-03400 09/29/2009 Adam Horowitz Bradley J. Edwards Activity in case 9:08-cv-80119- Joint-privilege
KAM Doe v. Epstein Response in
Opposition to Motion
03407-03414 09/29/2009 Bradley J. Adam Horowitz Activity in case 9:08-cv-80119- Joint-privilege
Edwards KAM Doe v. Epstein Response in
Opposition to Motion
03451.03452 05/14/2009 Bradley J. Spencer Kuvin Activity in Case 9:08-cv-80893- Joint-privilege
Edwards KAM Doe v. Epstein Order on
Motion to Stay
03477-03479 05/15/2009 Bradley J. Spencer Kuvin Activity in Case 9:08-cv-80893- Joint -privilege
Edwards KAM Doe v. Epstein Order to
Motion to Stay
03619-03627 09/15/2009 Bradley J. Spencer Kuvin BB v. Epstein/EW v. Epstein Joint-privilege
Edwards
03631-03633 09/15/2009 Jacquie Johnson William J. Berger BB v. Epstein/EW v. Epstein Joint-privilege
03646-03656 10/19/2009 Bradley J. Katherine W. Ezell Bill Riley's Subpoena & Depo Joint-privilege
Edwards Notice
03677.03687 07/08/2009 Bradley J. Adam Horowitz Can you send me those Joint -privilege
Edwards addresses?
03719-03736 09/04/2009 Bradley J. Spencer Kuvin CMA — depo notices attached. Joint-privilege
Edwards
03840-03847 08/02/2009 Stuart Bradley J. Edwards Continuing Deposition of Alfredo Joint-privilege
Mermelstein Rodriguez
03938.03939 09/29/2011 Katherine W. Bradley J. Edwards Deposition of Bill Riley Joint-privilege
Ezell
03943-03945 09/18/2009 Adam Horowitz Jacquie Johnson Deposition of lean Luc Bruhnel Joint-privilege
02911-02912 09/15/2009 Bradley J. Jack P. Hill Igor Zinoview depo Joint-privilege
Edwards
02939 07/14/2009 Bradley J. Adam Horowitz Jane Does 2-7 v. Epstein Joint-privilege
Edwards
02977 10/16/2009 Katherine W. Bradley J. Edwards Leslie Wexner Joint-privilege
17
EFTA00602851
Privilege Log — Dated 2-23-2011
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
Ezell
02978 10/29/2009 Bradley J. Stuart Mermelstein Leslie Wexner Joint-privilege
Edwards
02994 06/10/2009 Bradley J. Mercedes C. Preservation of evidence Joint-privilege
Edwards Estrada
07060 10/16/2009 Sid Garcia Bradley J. Edwards v. Epstein Joint-privilege
06202 07/13/2009 Richard Willits Bradley J. Edwards Scheduling various depositions Joint-privilege
regarding Epstein
06409.06415 04/15/2009 Bradley J. Katherine W. Ezell FYI Joint-privilege
Edwards
06428.06447 05/06/2009 Spencer Kuvin Bradley J. Edwards FYI Joint-privilege
06453-06454 04/15/2009 Spencer Kuvin Bradley J. Edwards FYI Joint-privilege
06465-06471 04/15/2009 Katherine W. Bradley J. Edwards FYI Joint-privilege
Ezell
06476-06490 05/08/2009 Bradley J. Spencer Kuvin FYI Joint -privilege
Edwards
06630-06632 09/09/2009 Spencer Kuvin Bradley J. Edwards Hearing to Un-seal Joint-privilege
06636-06639 09/09/2009 Bradley J. Robert C. Hearing to Un-seal Joint-privilege
Edwards Josefsberg
06702-06705 09/16/2009 Bradley J. Kikka M. Claudio Igor Zinoview & Tommy Matola Joint-privilege
Edwards depos
06706-06708 10/14/20
DataSet-10
Unknown
2 pages
From: Tonja Haddad Coleman ctl
To: "dkiesq'
Subject: FW: EDWARDS ADV. EPSTEIN--SERVICE OF COURT DOCUMENTS -
502009CA040800XXXXMBAG (File #: 291874)
Date: The, 17 Feb 2015 19:42:49 +0000
Attachments: Notice_of Cancellation_of Video_Deposition_Epstein-10311318.pdf
Tonja I lacklad Coleman, Esq.
TONJA HADDAD,
Advocate Building
315 SE 7th Street
Fort Lauderdale, FL 33301
Please add this efiling address to all pleadings:
The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If
you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If
you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message.
From: Mary E. Pirrotta [mailto
Sent: Tuesday, February 17, 2015 2:42 PM
To: 1.
'; Tonja Haddad Coleman; Tonja Haddad
Coleman
Cc: 'PBRS@Palmbeachreporting.comi; Chris S. Shelby
Subject: EDWARDS ADV. EPSTEIN--SERVICE OF COURT DOCUMENTS - 502009CA040800XXXXMBAG (File #: 291874)
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
502009CA040800XXXXMBAG
JEFFREY EPSTEIN v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M.,
individually
Notice of Cancellation of Video Deposition Epstein
Sent by: Jack Scarola (561)686-6300
Privileged and Confidential Electronic communication is not a secure mode of communication and may be
accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola
Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-
2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin.
2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is
not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this
communication is strictly prohibited. Personal messages express views solely of the sender and shall not be
attributed to the law firm. If you received this communication in error, please notify the sender immediately by
EFTA00714824
e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you.
EFTA00714825
DataSet-10
Unknown
7 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA-JOHNSON
JANE DOE NO. 2,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR
PROTECTIVE ORDER AND TO_QUASH SUBPOENA FOR
DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE
CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED
MEMORANDUM OF LAW IN SUPPORT
Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his
Response to Plaintiff's Motion for Protective Order and to Quash Subpoena for Deposition of
Jane Doe no.3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated
Memorandum of Law (hereinafter, the Motion"), with incorporated memorandum of law. In
support, Defendant states:
I. RESPONSE WITH INCORPORATED MEMORANDUM OF LAW AS TO
DEPOSITION OF JANE DOE. NO.3 AND MOTION TO CONSOLIDATE
a. The Depositions
Plaintiff, Jane Doe No. 2, filed this federal lawsuit against Defendant, Jeffrey Epstein. In
another separate matter, a Plaintiff, Jane Doe, No. 3., filed her own separate lawsuit against
Defendant, Jeffrey Epstein. Plaintiff's counsel represents all Jane Does in cases Jane Doe Nos. 2
through 7 before this court.
EFTA00729285
Page 2
Plaintiff, Jane Doe. No. 3, served answers to interrogatories wherein she lists certain
witness that may have knowledge regarding the facts and allegations alleged in her complaint
including, but not limited to, Jane Doe No. 2. See Exhibit "A", Answer to Interrogatories, No.
5, in redacted form. In particular, the response to interrogatory number 5 states that Jane Doe
numbers 2 and 3 accompanied each other to Defendant's estate. Plaintiff admits this much in her
Motion. Defendant seeks to take the deposition of Jane Doe. No. 3 as a witness in the instant
matter and as a party in Plaintiff her own case, which she is an unidentified Plaintiff traveling
under Jane Doe. No. 3.
In an attempt to resolve this matter by letter correspondence, Defendant agreed and
offered only to take the deposition of Jane Doe. No. 3 as a witness in all Jane Doe 2-7 cases only
one time and separately one time as a Party Plaintiff in the matter Jane Doe No. 3 filed against
Jeffrey Epstein. While this is a reasonable compromise in that Defendant has agreed not to take
her deposition three (3) times as Plaintiff suspected, Plaintiff's counsel refused to agree. Plaintiff
cannot file a lawsuit and then expect this court to protect her from being deposed as a party for
the time period proscribed under the federal rules while at the same time asking this court to
limit or prevent her deposition testimony as a witness in the instant matter or other Jane Doe
matters where she has been identified as a witness.
It is well settled that a Defendant may take the deposition of a party and/or a witness
before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp.,
43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2 and 3 commenced separate civil actions upon
the filing of same against Jeffrey Epstein. Therefore, Defendant is entitled to depose Jane Doe
Nos. 2 and 3 in their own cases at least one time for the proscribed time periods and then as a
witness in the instant matter or any matter they have knowledge of as reflected in the
EFTA00729286
Page 3
interrogatory responses. Therefore, Defendant has a right to depose each party-plaintiff
separately and then as a witness at least once. Deposing Jane Doe No. 3 as a witness in the
instant matter is necessary as that deposition will be tailored toward facts known by Jane Doe.
No. 3 as those facts pertain to Jane Doe. No. 2's claims in her complaint as opposed to the facts
alleged by Jane Doe. No. 3 in her individual action.
Plaintiff's attorneys claim that sitting for more than one deposition will be traumatizing
does not modify the rules and/or the law with regard to the right to take party and witness
depositions. Plaintiff offers no expert medical or psychological support, by an affidavit of an
expert or the Plaintiff herself, to support her position. In almost all instances, none of the
Plaintiff's sought or received any psychological counseling until the concept of a lawsuit and
money was introduced. A party may, by oral questions take the deposition of any person,
without leave of court. Rule 30, Fed.R. Civ.,P. Conducting these depositions separately will
allow for the proper preparation as to each deponent's knowledge as that knowledge pertains to
the specific case at hand (i.e., whether the deponent is a witness and/or a party plaintiff). Again,
Defendant is willing to conduct one (1) deposition in connection with each matter before this
court wherein a Party to one matter is listed as a "witness" in another. That is, if Jane Doe No. 3
has knowledge as a witness to one or more matters, one "witness" deposition will be held.
However, Defendant is also permitted to separately take a party-plaintiff deposition of any party-
plaintiff that happens to be a witness of and/or have knowledge of any other party-plaintiff's
deposition. As such, only two depositions will occur.
There is no legal basis supporting Plaintiff's proposition that Defendant not be allowed to
take the deposition of Jane Doe. No. 3 as a witness in the instant matter and as a party-plaintiff in
Jane Doe. No.3's separately filed action. In fact, Plaintiff's theory flies in the face of the Federal
EFTA00729287
Page 4
Rules. Despite Plaintiff's contention, Defendant is not attempting to depose or call a witness
for a second deposition without leave of court. Quite the opposite, Plaintiff is simply doing what
the rules allow for — the taking of a deposition of a party and a witness.
b. Consolidation For Discovery Is Not Practical
Next, if this case is consolidated for discovery purposes and depositions are limited only
to one (1) deposition for a party plaintiff and for a witness that happens to be a party plaintiff in
another matter, then confusion will result and motions in limine will undoubtedly be filed at a
later date preventing the use of certain testimony at particular hearings and ultimately at trial.
Further, since there remain separate party-plaintiffs, admissions or answers to discovery by one
party, arguably, cannot be used by the Defendant in a consolidated discovery matter against
another party-plaintiff. As such, consolidation in the instant matter is not warranted in that not
all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911
F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of
convenience of some witnesses, actions did not share all witnesses and parties were not
identical); Borough of Olyphant v. PPL Corporation et al. 153 Fed.Appx. 80, 2005 WL 2673489
(C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo 529 F.Supp.2d 535 (D. N.J. 2008).
Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery
is not mandatory but that decision remains within the sound discretion of the court. In this
instance, various Jane Does seek to consolidate the cases for discovery purposes. Very clearly,
the facts and circumstances, as pled and as is reflected in answers to interrogatories, are different
for each individual, i.e. the dates, the ages, the events, their experiences, witnesses, medical
and/or psychological treatment, etc. Each of the Plaintiffs alleged incident history and post
EFTA00729288
Page 5
incident history and background is unique to those individuals. While Jane Doe Plaintiffs may
wish to serve a "standard" set of interrogatories, request for production, or any other type of
discovery, the Defendant's discovery to the individual Plaintiffs, and certainly their responses, is
unique to that individual. There will be multiple instances where the discovery is applicable only
to a specific Jane Doe and not all, such as, physicians, psychologists, parents, siblings, friends,
employers, teachers, individuals with whom the Plaintiff has had relationships — many of these
depositions will go to damage related issues wherein the Plaintiffs seek millions of dollars in the
form of compensation.
There are some instances where the deposition of a particular individual may be
applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
Plaintiff's counsel that that particular deposition be used in all cases. However, in a vast
majority of the instances where discovery, deposition and/or paper discovery is being utilized,
including subpoena which will be sent to many different sources for each of the six Jane Does,
consolidation serves no purpose.
Even if this court consolidated the matters requested by Plaintiff, the undersigned would
still be entitled to additional time to depose any party-plaintiff that is also listed or who has
knowledge of any aspect of any other party-plaintiff's claim against Jeffrey Epstein. In addition,
this Court has before it each of the cases filed by certain Plaintiffs against Jeffrey Epstein.
Therefore, there is no chance of "conflicting results" as to rulings made by the same court and
the same judge. As such, no true need exists for consolidation. Under Fed.R.Civ.Pro. 42,
consolidation for discovery is not required, but remains within the sound discretion of the court.
EFTA00729289
Page 6
IL Conclusion
In sum, if Jane Doe No. 3 has knowledge as a witness to one or more matters, one
"witness" deposition will be held as to her witness knowledge. However, Defendant is also
permitted to separately take Jane Doe. No. 3's deposition as a party-plaintiff.
WHEREFORE, Defendant requests that this Court deny the Motion, enter an order
allowing for the relief requested herein and for such other relief as this court deems just and
proper.
Robert D. Critton, Jr.
Attorney for Defendant Epstein
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
day on all counsel of record identified on the following Service List in the manner specified by
CWECF on this day of April, 2009:
Stuart S. Mermelstein, Esq. Jack Alan Goldberger
Adam D. Horowitz, Esq. Atterbury Goldberger & Weiss, P.A.
Mermelstein & Horowitz, P.A. 250 Australian Avenue South
18205 Biscayne Boulevard Suite 1400
Suite 2218 West Palm Beach, FL 33401-5012
Miami, FL 33160
Co-Counselfor Defendant Jeffrey Epstein
Counsel for Plaintiff Jane Doe #2
EFTA00729290
Page 7
Respectfully submitted,
By:
ROBERT D. CRITTON, JR., ESQ.
Florida Bar No. 224162
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
Rillilliii i, LUTTIER & COLEMAN
515 N. Flagler Drive, Suite 400
3401
EFTA00729291
DataSet-10
Unknown
1 pages
From: Brad Edwards
Sent: Thursday, October 8, 2015 6:50 PM
To: Jeffrey E.
Subject: Re:
Been in deposition most of today. On break. 5:00, ok by me. =
Sent from my iPhone
On Oct 8, 2015, at 11:48 AM, jeffrey E. wrote:
that was helpful very, can i have until = pm?
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@gmail.com , and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA_R1_00148539
EFTA01803853
DataSet-10
Unknown
1 pages
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No: 10-80447-cv-Marra/Johnson
C. L.
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSMON OF:
NAME: DATE AND TIME: - LOCATION:
Maritza Milagros Vasquez May 18, 2010 Intelligent Office, 701 Brickell
10:00 AM Avenue, Suite 1550, Miami,
FL 33131
upon an oral examination before Videograpber and a Notary Public or officer authorized by law
to take depositions in the State of Florida. The oral examination will continue from day to day until
completed. The depositions are being taken for purposes of discovery, for use at trial or are being
taken for such other purposes as are permitted under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed thisZ
day of April 2010 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL .33401; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-
(561) 515-
By:
Spencer Kuvin, Esq.
Florida Bar No: 089737
EFTA00611588
DataSet-10
Unknown
58 pages
Condensed Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Plaintiff,
CASE NO.
-vs- 502008CA028051
X.XXXMB AD
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LARRY VISOSKI
October 15, 2009
10:18 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida
Reported By: Wendy Beath Anderson
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIREa* Alexarter Gallo Coop or
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA01110326
Larry ViSOSki October 15, 2009
3
I P4 114£ CIRCUIT COURT OP TIM TIPTIMITE J-3DICIAL CIKUIT 1 • . -
IN MD IOR MLR REACH 010.TY, PLOPZDA
CASE MO. 5020010101POSIx110111 AD 2 INDEX
3 • • •
4
Plaintiff. 5 WITNESS: DIRECT CROSS REDIRECT RECROSS
6
JeFTISC nmxx. LARRY VLSOSK1
Defendant. 7
BY MR. EDWARDS: 6
MOOStt10N OP LAY vilest! a BY MR. CRITTON: 214
rIturenay, October 15. 3004 BY MR. EDWARDS: 220
toils - 1:11 pa. 9 BY MR. CRITTON: 221
10
511 N. Plagler Drive 11
Suite Me
Neer MIN. Satoh, florid.. 1)401 12 • • •
13 EXHIBITS
1141p9ftej Sy, 14 • • -
Wendy death Anderson, RPR, CRR. PPR 15
votary Public, State Of Plorida
,racialre Direesttlen Ninglowil 16 NUMBER DESCRIPTION PAGE
int pale brad, Office Jeb 113)541 17 PLAINTIFFS EX. 1 FLIGHT LOG BOOT(
(MARKED IN PREVIOUS DEPO)
28
19 PLAINTIFFS EX. 2 MESSAGE PAD 119
PLAINTIFF'S EX. 3 MESSAGE PAD 119
20 PLAINTIFF'S EX. 4 COMPLAINT 139
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161
21
22
23
24
25
2 4
APPEARANCES: 1 PROCEEDINGS
On behalf of the Plaintiff: 2 ...
BRADLEY J. EDWARDS. ESQUIRE
T ADLER 3 Deposition taken before Wendy Beath Anderson.
4 Certified Rash'rne Reporter and Notary Pudic in and for
5 the State of Florida at Large. in the above cause.
6 ---
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE 7 MR. EDWARDS: We're going to put something on
ITT 8 the record about -- well, we'll do it this way -
9 MR. REINHART: Do it at the end, alter we get
10 10 him -- whatever you want. It's your show.
12 On behalf of die Witness: 11
12 MR. EDWARDS: Okay. There were -- I don't
12 oven think Mr. Welds Is aware of this. There was
13 13 a subpoena duces team for this witness, as well as
1111= 14 the previous witness, which was another pilot. Dave
14
as ALSO PRESENT: is Rogers. and that duces tocurn was to bring the
16 MES E UtRE
16 flight logs related from 1998 through 2005. What
17 27 was produced at the previous deposition were flight
is
TIME i R WITZ PA. 1$ logs from 2002 through 2005, and now Mr. Reinhart
19 19 has agreed to produce the remainder of the flight
20 logs requested, those going from 1998 through 2002.
20
RICHARD H. WILLITS. ESQUIRE (VIA TELEPHONE) 21 MR. REINHART: Correct. They're pilot logs,
22 A P.A. 22 not night logs. There are other records we
22 23 Indicated are corporate records, and with those you
23 24 have to deal with Mr. Critton.
24
25 25 MR. CRITTON: However, with the proviso, too,
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE Oalloo ComPal
4440 PGA Boulevard
Palm Beath Gardens, FL 33410
vnvw.esquiresolutlons.com
EFTA01110327
Larry Visoski October 15, 2009
5 7
that we're going to work out that these records are 1 the question and you need to wait until I finish asking
to be used within the confines of this litigation 2 the question.
and not to be spread to the press or anyone else. 3 A. So yotfre not allowed to interrupt me?
because they do contain confidential information as 4 O. And you're not allowed to interrupt me.
to who may have been on the plane and other records 5 A. Like I just did?
of Mr. Rogers, which but for the subpoena would 6 O. Right.
have been only available to the FAA or some other 7 MR. CRITTON: Cara just snickered when you
law enforcement agencies. a said yotfve been accused because she recognizes
9 MR. EDWARDS: Okay. Is that all you want to 9 irs true.
10 put on? 13 MR. EDWARDS: I don't know what the meaning of
11 MR. CRITTON: Yes. 11 her snickering was.
12 MR. EDWARDS: I'm not saying I necessarily 12 BY MR. EDWARDS:
13 agree or disagree with you. Thais something that 13 Q. But for what ifs worth, if you don't
14 well deal with some other day. 14 understand the question or I've asked a bad question, I
15 MR. CRITTON: Bruce, you'd better produce 15 don't want you to guess. Give me the best answer to the
16 these records, but there has to be some sort of 16 best of your knowledge and if you need me to rephrase
17 understanding before - 17 rt. I wilt
18 MR. REINHART: Correct. 18 A. Okay.
19 MR. EDWARDS: I won't do anything until you 19 O. Okay. Tell me your current address.
20 file whatever you - until we work whatever it is 20 A
21 out in court. ill say that on the record, that
U
22 I'm not doing anything with the records outside of 22 Q. How long have you lived there?
23 my office until some Judge deals with It. 23 A. Approximately nine years.
24 MR. REINHART: And for the record, I'll adopt 24 Q. Okay. Who do you live there with?
25 what Mr. Craton said on this one limited occasion. 25 A. My wife and one chid al this tine.
6 8
MR. EDWARDS: Al right. 1 O. All right. How many children do you have?
2 Thereupon. 2 A. Two.
(LARRY VISOSKI) 3 Q. How old are they?
4 having been first duly sworn or affirmed, was examined 4 A. Fifteen and eighteen.
5 and testified as follows: 5 Q. And is the 18-year-old, is not living with
THE WITNESS: Yes, I do. 6 you?
DIRECT EXAMINATION 7 A. She's off in school.
8 BY MR. EDWARDS: a Q. Okay. What school Is that?
9 Q. Can you tell us your name for the record 9 A. Syracuse.
10 A. Lawrence Visoski, Jr. 10 Q. Who's your employer right now?
11 Q. And Mr. Visoski, have you ever had your 11 A. NES, LLC.
12 deposition taken before? 12 Q. How long has NES, LLC been your employer?
13 A. No. 13 A. I'm guessing. I'd say back 1991. I have to
14 O. Okay. Here's the process: I'm going to ask 14 do the math, but 17, 18 years.
15 you questions. You're going to give us answers. Try to 15 O. Has that been your only employer since 1991?
16 give us answers that we all understand and that the 16 A. Yes.
17 court reporter can take down, such as yes, no. or some 17 O. And has that been your only source of income
18 other verbal answer that we can understand. It's easy 18 since 1991?
19 when we get in a casual conversation to nod or shake 19 A. Yes.
20 your head, and the court reporter is not writing 20 Q. And what is NES, LLC?
21 pictures or anything else. 21 A. I don't really know. I mean, rt's the company
22 A. I understand. 22 that my check comes from.
23 O. The other thing is, and I've been accused of 23 Q. What do you do for NES, Lie that results in
24 this In other depositions -- I donl know if it's true 24 them paying you?
25 or not -- but I need to wait until you finish answering 25 A. I am chief pilot for the aircraft and
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIR
.m E 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
irnvw.esquiresolutIons.coM
EFTA01110328
Larry Visoski October 15, 2009
9 11
. helktopters. 1 O What floor or suite number is NES. LLC In?
0. And do you have a specific boss or somebody 2 A. I believe — well, I don't know that NES, LLC
you answer to at NES, LLC? A has an office there. I know that's where Leslie has the
A. Several people would call to schedule flights 4 phone number where I call So I don't know for a fact
from the office, being it either Mr. Epstein or, you 5 rf NES. LLC has an office there.
know. I would lust get a phone call and they would 6 O. And whet suite number, then, would Leslie
schedule a trip. 7 Gruff sit in to answer that telephone number at
Q. Okay. Aside from Mr. Epstein, who else would MIM
A. I think It's 10F.
9 there be that would call to schedule flights? 9
10 A Leslie. 10 Q. And when you stay a
11 0. Leslie who? 11 what suite number or what apartment number do you stay
12 A. Leslie Gruff. 13 in?
13 Q. When's the last time you talked to Leslie 13 A. 12C.
14 Gruff? 14 0. And how about Dave Rogers, where does he stay?
15 A. Probably two weeks ago, three weeks ago. 15 A. I'm guessing, because it's been some time
16 Q. And where is she currently? 16 since we've been there, 108, but don't quote me on
17 A. I believe in New York, is where I spoke to her 17 0. Who are the other people in that building that
18 on the phone last. 18 you know to stay there on a reguku — fairly regular
19 Q. What's the telephone number you call to reach 19 basis?
20 Leslie Gruff? 20 A. the seen people in the elevator that. you
21 A. 21 know, have been on the airplane. Case in point. maybe
22 Q. And what address is Leslie Gruff at? 22 but I dorYt know totaled that she Wes
23 A. Do you mean where the office Is located? 23 there, or anybody else for that matter.
24 0. Correct 24 0. Okay. When you say you've mein..
25 A. 25 on the elevator
10 12
1 0. And It's my understanding from other A. I only assume she Wes there. I don't know
2 depositions that there are also apartments In trial. 2 for a fact. rm hying to be honest and factual for
building? 3 you. So I couldn't honestly say if I knew she lived
4 A. Yes. 4 there or not
5 Q. And Mr. Epstein either owns or leases or rents 5 0. Where do you thine Wes?
6 certain of those apartments. Is that your 6 A. I would think she lives there.
7 understanding? 0. You don't have a bettor location?
a MR. CROTON: Form; speculation. 8 A. I don't have another location.
9 THE WITNESS: I'm only speculating. I 9 0. Anybody else?
10 don't -- to my understanding, I don't know. 2o A. Not to my knowledge. I mean, I'd only be
11 BY MR. EDWARDS: 11 guessing that people We in that builckng that -- you
12 0. Do you know other people that live in that 12 know, I don't have any facts to prove that they actually
13 building? 13 live there. I mean, I don't think you want me to guess.
14 A. Well, it would be myself. Dave Rogers - wet 0. Well, NES, LLC, would you say that the owner
35 when you say "live,' explain. 15 or controller of that company Is Jeffrey Epstein?
16 0. When you're saying yourself and Dave Rogers - 16 MR. CRITTON: Form.
17 A. See, we don't live there. I mean, we have -- 17 THE WITNESS: I don't know that for a tact.
18 we would stay there when we would have a trip. 1e BY MR. EDWARDS:
19 Q. Okay. When you would fly up to New York and 19 0. Jeffrey Epstein is somebody you've Indicated
20 land in New Yogic, the place where you would stay, is 20 that you've worked for for 17 or 18 years, right?
21 the 21 A, Yes.
22 A. Yes, that's corned. 22 0. And over the 17 or 18 years you've become
23 0. That's also a location you've indicated in 23 personally close with him as wee, correct?
24 this deposition that Is the office for NES, LLC? 24 MR. CRITTON: Form.
25 A. Yes. 25 THE WITNESS I Oaf* understand how you mean
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE •• SOM.!. Oal *U./al
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esqulresolutlons.com
EFTA01110329
Larry Visoski October 15, 2009
13 is
1 'dose.' Define that. 1 you know. televisions and such.
2 BY MR. EDWARDS: 2 O. Is that another hobby or job or something of
3 a Wel, rpm so than just a pilot that takes him 3 yours?
4 from Point A to Point B? 4 A. Both.
5 A. That is my job. 5 O. Does he pay you for that?
6 O. Right. But you know him on a personal level 6 A. Not any more than my salary.
7 and that you've had personal conversations that don't 7 O. What's your current salary?
8 necessarily deal with flying from Point A to Point B; A. At this time, 180,000.
9 isn't that right? 9 O. And what aro you paid $180,000 to do?
10 MR. CRITTON: Form. 10 A. To manage his aircraft.
11 THE WITNESS: More specific, meaning we talk 11 O. What does that entail?
12 about cars. I mean, does that make you a personal 12 A. Schedufing maintenance. Anything that has to
13 friends? 13 do with any flight, whether it be weather, flight
14 BY MR. EDWARDS: 14 planning, time and distance to and from a location, any
15 O. Have you ever gone to his house to eat? 15 logistics involved In running an operation that has
16 A. No. 16 aircraft.
17 O. Have you been to his New York home? 17 O. In addition to the 180,000, does he give yc.
18 A. Yes. 1$ bonuses as welt?
19 O. How many occasions have you been to his New 19 A. There have been Christmas bonuses.
20 York home? 20 O. Over the years, you mean, there have been
21 MR. CRITTON: Object to form. 21 Christmas bonuses?
22 THE WITNESS: We normally pick up luggage In 22 A. Yes.
23 the lobby, so it would probably be quite often. 23 O. Is 180,000 the most he's ever paid you?
24 Any time we depart out of New York, we stop by the 24 A. No.
2S house and pick up luggage and head to the aircraft. 25 O. All right Were you making when was the
14 16
BY MR. EDWARDS: 1 last time that you were making an amount different than
2 O. Other than picking up luggage, have you been 2 180,000?
3 to his home to visit or socialize with him? 3 A. Last year.
4 A. Not to socialize, no. 4 O. That would be 2008?
s a Have you been to his Palm Beach home? A. That would be correct. Yeah, we all took a
A. To? 6 salary cut, I don't know the exact date. It might have
O. To Mr. Epstoin's Palm Beach house? 7 been 2008, last year. It was last Christmas wo all took
8 A. Right. 8 a 10 percent salary cut.
9 O. Have you been there? 9 Q. Do you know why?
10 A. Yes. 10 A. Economic reasons.
11 O. Have you been inside? 11 O. And who told you that you were going to have
12 A. Yes. 12 to take the salary cut?
13 O. And how many occasions have you been inside 13 A. Darren Indyke.
14 that home? 14 Q. And did you ask for an explanation?
15 A. The same, as far as picking up luggage, and 15 A. lie explained it was due to economic reasons
16 that would be on a regular basis, you know, for a 16 throughout the country.
17 departure. We wouldn't always go to the house to pick 17 O. Okay. So In 2008, how much was -- were you
18 up luggage, but it made it easier for loading the 18 being paid by NES, LLC?
19 aircraft getting it done prior to departure. 19 A. 200.000.
20 Q. Is that the only reason that you have ever 20 O. And is 200,000 the most that you've ever made
22 gone to the Palm Beach home over the last 18 years. is 21 from NES, LLC?
22 to pick up luggage? 22 A. Yes. sir.
23 A. No. 23 O. And on top of that $200,000, did you get a
24 Q. What other reasons have you gone there? 24 bonus that year as well?
25 A I've set up several home theater equipments. 25 MR. REINHART: Which year are you bildng
Toll Free: 866.709.8277
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
veew.esquiresolutions.com
EFTA01110330
Larry Visoski October 15, 2009
17 19
about? 1 my paycheck. So I don't even know what's written on the
MR. EDWARDS: 2008. 2 lop of it.
THE WITNESS: That year, I think we skipped 3 0. That would be something that only your wife
Christmas bonuses that year. The last bonus might 4 would see. I'm assuming?
have been 2007. 5 A. You're right, since she probably wouldn't know
BY MR. EDWARDS: 6 the answer either, because she's looking et the right
Q. If you ever got a bonus from Mr. Epstein — 7 column and not the top column.
and I'm only deriving this from you using the term a 0. Right. When is the first time that you had
9 'Christmas bonus' 9 heard the name NES, LLC, that company?
10 A. Holiday bonus. 10 A. Fwe. Six years, and even questioned what'd
11 Q. -- am I correct to assume sorry. Am I 11 stood for. And I think to this day I couldn't answer
12 correct to assume that if you got a bonus, there was 12 that honestly, what It stands for.
13 only one and it was at the end of the year, around the 13 0. Okay. But it's your understanding that the
14 holidays? 14 NES, LLC is paying you for the work that you do as a
15 A. Yes. 15 pilot or maintain the planes for Jeffrey Epstein?
16 Q. Okay. And how much was the 2007 holiday 16 A. To my understanding, yes.
17 bonus? 17 a And back In 1991. do you know If It was a
18 A. I'd have to ask my wife. to be honest. I 18 dffereert company that was paying you or if it was
19 haven't seen my paycheck in 27 years. so I believe it 19 Jeffrey Epstein directly paying you?
20 was 310.000. 30 A. I don't remember. I mean, I don't
21 Q. And in 2007 you also made $200,000? 21 0. Okay. Throughout your career with -- as a
22 A. Yes. 22 pilot laJeffrey Epstein, since 1991, has there ever
23 Q. Okay. 23 been a time when you believe you we paid directly from
24 A. With a question mark. I'm trying to be as 24 Jeffrey Epstein personally versus some company?
25 accurate as I can, but yes. 25 A. Not to my kncrertedge, no.
18 20
0. Something pretty close to mat? 0. Okay. So whether s was NES. LLC or some
A. Yes, sir. 2 other company, it was all of a sudden a company name, to
0. Okay. So with the bonus it was 210,000. 3 the best of your linoviedge?
roughly? 4 A. Exactly, yes.
5 A. Right. 5 0. And back in 1991, do you remember
0. Okay. And how long were you making that 6 approximately how much you were being paid that year?
salary? 7 A. Fifty-live or 80.000. is maybe what I started.
A. Probably -- he was very religious about giving 8 0. Okay.
9 annual increases. so I would probably say 2006, you A. You're going back a long ways.
10 know. It was -- we would get Increment increases of 10 0. Yes.
11 five or $10,000 each year. So I would say 2006. So it 11 A. I'm trying.
12 graduated. you know, progressive. 13 0. Your relationship goes back that far. There
13 0. Okay. Do you remember the progression if we 13 why I those that year.
14 start at 1991? Do you remember roughly what the 14 A. Right.
15 progression was up through 2007/2008, when you were 15 0. Okay. Did you get bonuses even back that far?
16 making $200,000? 16 A. Yes, sir.
17 A. No, I wouldn't know the progression. 17 0. And do you remember what your bonuses were
15 0. Okay. Do you remember what you were making as approiknately?
19 from -- and was NES, LLC the company paying you back in 19 A. 5,000. I mean. that was laird of the — the
20 1991? 20 starting point.
21 A. I don't know. I don't remember. Let me say 21 0. Okay. In addition to moneary bonuses. were
22 it that way. I don't remember. 22 there ever gifts or any other type of compensation that
23 O. Okay. When how long do you remember NES, 21 NES, LLC or Jeffrey Epstein provided you?
24 LW being the payer of your check? 24 A. Yes.
25 A. Personally, two years. because I've never seen 25 0. And is that over the span of the 18 years?
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE a* A nat. Gall* Ceasan
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutIons.coM
EFTA01110331
Larry Visoski October 15, 2009
21 23
A. Yes. 1 Q. But more so than that, if there's going to bo
O. Okay. Ten me what some of those items are. 2 a casual conversation about a peel or a pool heater or
A. I remember one specifically was a pool heater. 3 whatever, Ws going to be with you most likely if he's
Q. Excuse me? 4 going to be talking to pilots, right?
A. A pool heater. 5 MR. CRITTON: Form.
Q. When was that? 6 THE WITNESS: Right.
1995-ish. 7 BY MR. EDWARDS:
Q. Okay. Why did you get that? O. Okay. And you feel like over the years yoke
9 A. I had built a pool and I didn't have a heater 9 relationship with Jeffrey Epstein has boon pretty good?
10 and he kind of laughed at me saying, 'How can you have a 10 A. Yes.
11 pool without a heater?' So he says, 'You ought to get a 11 O. And you have been closer to him over the years
12 heater." 12 as you've grown to know him?
13 Q. Where were you when you had that conversation? 13 MR. CRRTON: Form.
14 A. In the airplane. 14 THE WITNESS: The same throughout the same
15 O. How ofd he know that you had bunt a pool? 15 year. We never got any closer than 1991 than I am
16 A. Just in general conversation, 16 wilt him now. I'm very professional at what I do
17 O. You were having a conversation with Jeffrey 17 and know the line between being professional and
18 Epeteli? 18 thinking you're somebody's buddy.
19 A. Yes. 19 BY MR. EDWARDS:
20 O. And this is something that was happening on 20 O. Okay. So thars not something that you think
21 the airplane, this conversation? 21 you are? You don't think you're his buddy?
22 A. Dung the flight Yeah, It would have been 22 A. No, sir.
23 We on cruise or something. 23 O. Do you consider yourself his friend?
24 Q. Okay. When you say during the flight,' does 24 A. I believe so.
2s that — 25 Q. Do you think he considers you his friend?
22 24
A. Again, you're going back a long ways. 1 A. I think so.
2 O. I understand. We're larking about 1995 right 2 O. All right. What makes you think that?
now. 3 MR. CARTON: Speculation.
A. Yes. 4 THE WITNESS, He's always been kind and
5 O. You're having a conversation with Jeffrey 5 respectful.
6 Epstein. Who is flying the airplane? 6 BY MR. EDWARDS:
7 A. The auto pilot and there's two crew. O. Ever invited you to dinner?
8 O. Okay. So are you back in the back portion or A. No, sir.
9 Is he up In the cockpit? 9 Q. Have you ever associated or socialized with
10 A. Up in the cockpit. t0 him during the day at any of his homes?
11 O. Okay. Jeffrey Epstein sometimes comes up 11 A. Only during a business reason.
12 there? 12 O. Okay. What are the other are the places
13 A. Just, yeah, in between the two pilot seats. 13 that you believe that Mr. Epstein owns? I know we've
14 Q. All right. Is that something that was 14 talked about this Manhattan -- the Manhattan house.
15 typical, to have conversations like that? IS I've read the altos about it, the Palm Beach mansion.
16 A. Mm-hmm. 16 But what other places are you familiar with that
1? O. Yes? 17 Mr. Epstein owns?
18 A. Yes. No nodding. 18 MR. CRITTON: Form; predicate, speculation.
19 O. And woukl those conversations be directed 19 THE WITNESS: To answer it honestly. I don't
20 mainly with you or with the other pilots as well? 20 know specifically that he owns any of the
21 A. Mainly with me. 21 residences, to be honest. I would only assume that
22 Q. I mean, you've kind of been described as the 22 he owns. So if you want me to answer honestly. I
23 main guy or the main pilot. Wouldn't you consider that 23 don't know that he owns any of the other.
24 pretty much your role, right? 24 BY MR. EDWARDS:
25 A. Well, that's chief pia 25 Q. Okay. Well, what would be the basis for your
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIR
nA""...“E
_."
4440 PGA Boulevard
Palm Beach Gardens, Ft. 33410
www.esquiresolutlons.com
EFTA01110332
Larry Visoski October 15, 2009
25 27
assumption that he owns the home in Pakn Beach? 1 O. Am those private airports?
2 A. He goes there, but I don't assume -- you don't 2 A. Public.
a have to own a house to go to it. 3 O. Public, okay. Are there any private landing
Q. And not only does he go there, you're aware places where you would land any airplanes in New Mexico?
that he spends the night there: he resides there 5 A. There are.
6 sometimes, correct? 6 0. That you have landed
A. Yes. 7 A. That I have.
5 0. When he's in Palm Beach, Mat's where he — 0. - his airplane?
9 A. He sloops. 9 A. Yes.
10 0. sleeps? Right. When he's in New York, do 10 0. Where?
11 you know where he sleeps? 11. A. We have a 4500-foot strip on the ranch.
12 A. No. 12 0. When you say 'we.' yourself and somebody'
13 Q. But you've been to a particular house in New 13 A. The company.
14 York that's a very large house that we've all read about 14 Q. What company?
15 that you picked up luggage at, right? 15 A. Well. I should say I see where you're going
16 A. Yes, sir. 16 waft that. The ranch owns — whoever owns the ranch.
17 MR. CRITTON: Form. 17 The ranch has a runway on it.
18 BY MR. EDWARDS: 16 Q. Okay. And you've landed an airplane on that
19 0. And that home, do you know that — I know that 19 noway?
20 you're saying that you haven't done a public record 20 A. That ranch. yes.
21 search to make sure that Jeffrey Epstein owns it. 21 Q. How many times do you think you've landed
22 A. Yeah. 22 there?
23 0. But you assume that he does? 23 A. Ten.
24 A. Assuming. 24 Q. All right. And have you been inside his
25 0. That's where he sleeps when he's in New York? 25 ranch?
26 28
MR. CRITTON: Form. 1 A. Yes.
2 THE WITNESS: I assume. 2 MR. CRITTON: Form to the last question.
3 BY MR. EDWARDS: 3 MR. REINHART: Can you clarify, the physical
4 0. That's where his luggage is when you pick it 4 ranch or the residences or the structures on the
up? 5 ranch?
6 A. Doesn't mean he owns It. 6 MR. EDWARDS: I don't have a good visual
0. Right. But that's where it is? 7 appreciation for it.
A. Yes, sir. 8 BY MR. EDWARDS:
9 0. Do you know of anybody else who owns that home 9 Q. Why don't you describe it in your words what
10 in New York? 10 this ranch Mal We are talking about looks like. And
11 A. No. 11 I've heard it referred to as the Zorro Ranch. Have you
12 0. Okay. Have you been to his ranch in New 12 heard that?
13 Mexico? 13 A. I've heard that.
14 A. Yes. 14 0. That's the ranch we're all familiar with,
15 MR. CFUTTON: Form. 15 we're talking about where the runway is and everything
16 BY MR. EDWARDS: 16 else?
17 0. How many times have you been to his ranch in 17 A. Yes.
18 New Mexico? 18 0. Describe it in your own words, the landscaping
19 MR. CRITTON: Form: predicate. 19 of this ranch. What do we have on it?
20 THE WITNESS: A guesstimate. fifty times, only 20 A. There is a house up on the hal, a large
21 due to the fact that we would fly there. 21 house.
22 BY MR. EDWARDS: 22 O. How big?
23 0. And where would you land? 23 A. Big. I've read 40,000 square feet In the
24 A. Depending upon the aircraft, either 24 paper.
25 Albuquerque or Santa Fe. 25 O. Have you been to it?
Toll Free: 866.709.8777
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ESQUIRE 4440 PGA Boulevard
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Larry Visoski October 15, 2009
29 31
1 A. Yes. 1 A. Yes. sir.
2 Q. Does that seem like it's feasible, 2 Q. And he sleeps there?
3 approximately 40,000 -- 3 A. Yes.
4 A. I think so. yes. 4 Q. Okay.
5 Q. What else do we have on it? A. I assume he does.
6 A. There Is a compound that hes kind of motel 6 0. You assume he sleeps?
7 room type -- they call it bunkhouse. 7 A. I do. I think.
8 0. Where's the bunkhouse located? 8 Q. Okay.
9 A. At the entrance to the ranch. 9 MR. CRI1TON: This Is really --
10 0. Okay. And what Is that primarily used for? 10 BY MR. EDWARDS:
11 A. For the people that work on the ranch, they 11 0. Other than the pool heater in 1995. have you
12 reside there. It's also a place where anybody that 12 ever received any other gifts on top of the compensation
13 traveled on the airplane would stay. It's lTd of Eke, 13 from Mr. Epstein?
14 you know, a hotel room. 14 A. I did get land on the ranch to build a house.
15 0. And how far is that from the first house that 15 Q. What do you mean you got land on the ranch?
16 you deserted, the 40.000 square foot house? 16 A. He deeded me land to build a home.
17 A. Its probably 4 miles. 17 Q. When was that?
is Q. Okay. So the Zone Ranch is a rather large 1$ A. Ten years ago at least
19 area of property? 19 Q. Do you know 4 he's ever deeded anyone else in
20 A. Yes. 20 this world land on the ranch to bultd a home?