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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
Plaintiff,
- vs- VOLUME III OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OFIIII.
Tuesday, February 09, 2010
10:09 - 5:05 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1296
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1 APPEARANCES: 1 PROCEEDINGS
2 On beJulf ofthe Plaintiff lig! and Jane Dot 2
3 BRAD J. EDWARDS,
FARMER, JAFFE, WEISSItla EDWARDS 3 THE VIDEOGRAPHER: This is the 9th day of
4 4 February, 2010. The dine is approximately
5 10imIty.m. This is the videotaped deposition
6 OM. in the matter of M. versus Epstein.
I 7 This deposition is being held at 250 South
On of tbe Jeffrey Epstein:
ROBERT D. CROTON, JR., ESQUIRE 8 Australian Avenue, West Palm Beach, Florida.
MARK T. LUTHER. ESQUIRE 9 My name is Daniel Downey, I am the
9 LUITIER ea COLEMAN, LLP
10 videographer representing Visual Evidence,
11 Incorporated. Will the attorneys please
12 announce their appearances for the record.
•2 On bed o • • licfrroYEPslele: 13 MR. EDWARDS: Brad Edwards on behalf of
.3 JACK ALAN GOLDBERGER, ESQUIRE 14
ER Fe WEISS. PA
14 15 MR. LUTTLER: Mark Luttier with the firm
16 of Burman, Critton, Luther & Coleman on behalf
17 of Mr. Epstein.
16 18 MR. CRITMN: Bob Critton on behalf of
17 19 Mr. Epstein.
18 ALSO PRESENT: kffrey Epstein, via video conference
Daniel Downey, Videograplicr 20 Thereupon,
19 Visual Evidence, Incorporated 21
20 22 Having been first duly sworn or affirmed, was
21
22 23 examined and testified as follows:
23 24 THE WITNESS: I do.
24
25 25
Page 338 Page 340
1 1 DIRECT EXAMINATION
2 2 BY MR. LLTIT1ER:
3 INDEX VOLUME I 3 Q. Good morning, Ms... We're here for the
4 4 continuation of your deposition that was started on
5 5 September 24th, 2009. Do you understand that you're
6 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 still under oath today?
7 7 A. Yes, sir.
8 BY MR. LUTHER 4 8 Q. Have you had an opportunity to reviewa
9 9 transcript of that portion of your deposition which
10 10 has been completed thus far?
11. 11 A. Yes, sir.
12 NO EXHIBITS MARKED 12 Q. Have you reviewed the full transcript?
13 13 A. Yes, sir.
14 14 Q. And were there any corrections in your
15 15 testimony?
16 16 A. Were there any corrections in my testimony?
17 17 Q. In other words, when you read it did you
18 18 see anything that was incorrect?
19 19 A. No, sir.
20 20 Q. Do you recall whether or not you silted
21 21 the transcript indicating that all of it was
22 22 accurate?
23 23 A. I signed, yes.
24 24 Q Do you know if the original got sent
25 25 anywhere or do you stil I have it or dicliou just
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1 give it to your lawyer? 1 shown to third parties and they had been asked
2 A. I gave it to my attorney. 2 whether or not they wanted to purchase an interest
3 Q. And you signed it without any corrections? 3 in your lawsuit?
4 A. Yes, sir. 4 A. No.
5 Q. Have you ever been to Mr. Edwards' former 5 Q. No one had called you and advised you that
6 law firm's office in Fort Lauderdale? That would be 6 your files were being shown to anybody?
7 the firm of Rothstein, Rosenfeldt & Adler. 7 A. No.
8 A. What is this address? Is this address on 8 Q. Have you had any discussions with anyone
9 Andrews? 9 about that issue?
10 Q. 10 A. No.
1/ A. No. 11 Q. And when I say anyone I mean
12 Q. Have you ever been to a law firm where 12 representative of the Florida Bar Association; have
13 Mr. Edwards was practicing while he's been 13 you had any discussions with anybody from the
14 representing you where there are other lawyers 14 Florida Bar?
15 besides himself present? 15 A. No, sir.
16 A. No. 16 Q. Any discussions with anybody from the FBI
17 Q. Does the name Rothstein ring a bell to 17 about that specific issue?
18 you? Do you know who that is? 18 A. About what issue, about getting —
19 A. No. 19 . Q. About someone attempting to purchase an
20 Q. Do -- have you ever met with anyone else 20 interest in your lawsuit.
21 other than your lawyer with respect to the merits of 21 A. No.
22 this lawsuit and whether or not you believed you 22 Q. Anyone from the State Attorney's office?
23 were likely to recover money in this case? 23 A. No.
24 A. No. 24 Q. Okay. Prior to coming here today, have
25 Q. Has anyone ever approached you arid -- 25 you had an opportunity to review a transcript of a
Page 342 Page 344
1 other than your lawyer -- and discussed with you the 1 hearing that was held before the court on
2 merits of this case or whether or not you believed 2 November 3rd, 2009, upon your motion to terminate
3 you were likely to recover money? 3 the continuation of this deposition?
4 A. No. 4 A. Excuse me?
Q. Have you been advised that — or let me 5 Q. Prior to coming here today have you been
6 strike that. Have you been provided any information 6 provided an opportunity to review a transcript of a
7 that your case and the information contained in it 7 hearing that was held before the court on
8 was made available to third parties to review to 8 November 3rd, 2009, on your motion to limit this
9 determine whether or not they wanted to purchase an 9 deposition?
10 interest in the outcome of your case? 10 A. I'm not understanding this.
11 A. No. 11 Q. You know what a transcript is, don't you?
12 Q. Have you, prior to me just asking you that 12 A. A transcript, yes.
13 • question, did you know that that had occurred? 13 Q. This would have been a transcript or
14 MR. EDWARDS: Object to the fonn. 14 written record of a court hearing that we had in
15 THE WITNESS: Excuse me? 15 case on November 3rd, 2009, that concerned the
16 MR. EDWARDS: I objected to the form of 16 conducting of this deposition. Have you seen any
17 the question. It assumes that it did occur. 17 such transcript?
18 BY MR. LUITIER: 18 A. A transcript of what?
19 Q. Before I asked you that question, did you 19 Q. Of that court hearing.
20 know that that had occurred. 20 A. Of what court hearing?
21 A. Sr, I'm not really understanding what you're 21 Q. The one that was held on November 3rd,
22 saying. 22 2009.
23 Q. All right. Let me repeat it. 23 A. That we recently just did, my last deposition?
24 . A. Okay. 24 Q. No. The, the hearing was held on
25 Q. Did you know that your case tiles had been 25 November 3rd, 2009. The subject matter of the
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1 hearing was a motion that was filed by your lawyer 1 was 13 years old. And on that note, he took it from
2 to limit the continuation of this deposition. 2 there to just comfort me through the, through the pain
.3 A. Yes. I knew that we were going to have 3 that I was going through and that I have been going
4 another deposition. 4 through.
5 • Have you seen the transcript of that 5 Q. Did any of these discussions concern
6 hearing wherein the judge gave some specific 6. anything else?
7 direction to you and your conduct in the 7 A. No, sir.
8 continuation of this — 8 Q Have you, since your deposition on
9 A. Yes. September 24th, 2009, had any type of contact with
10 Q. deposition? 10 anyone else who has filed asuit against
11. A. Yes. 11 Mr. Epstein?
12 Q. Okay. So you're aware of that? 12 A. Yes.
13 A. Yes. 13 Q. M.Who have you had contact with?
14 Q. Okay. Are you still living at the same 14 A
15 address that you gave me at the last deposition? 15 Q. Anyone else?
16 A. Yes, sir. 16 A. No, sir.
17 Q. Who else is living with you there now? 17 Q. And when I, I use the word contact, by
18 A. My son. 18 that I mean could be face-to-face contact, could be
19 Q. Anyone else? 19 a conversation, could be some sort of computer,
20 A. No, sir. 20 computer message, a text, Twitter, e-mail, any kind
21 Q. Has anyone else lived with you at that 21 of commuter — anything like that, could it be, it
22 address since your deposition on September 24th, 22 could be something in writing. Do you understand
23 2009, other than your son? 23 that's What I mean by communication?
24 A. No, sir. Since November, actually, Thomas 24 A. Yes, sir.
25 Souder, he had moved, he lived with me until 25 Q. And so the only person since September
Page 346 Page 348
January 1st, 2010. 1 24th, 2009,. that. yo_u had any contact with that has a
2 Q. And am I correct told us at your 2 suit pending against Mr. Epstein is E.?
3 last deposition that was then your 3 A. Yes, sir.
4 current boyfriend? 4 MR. CRITION: No, Mr
5 A. Yes. 5 THE WITNESS: No.
6 Q. Has that relationship changed now? •6 MR. CRITTON: What.did she say?
7 A. Yes. 7 THE WITNESS:
,8 Q. He is no longer your current boyfriend? 8 MR. LUU1ER:
A. Correct 9 MR. CRITTON: Oh,
10 Q. Is the apartment that you currently live 10 MR. LUTIIER: Yeah.
11 in, is that a rental apartment? 11 MR. CRITTON: Okay.
12 A. Yes. 12 MR. LUITIER: And when did you
13 Q. Is that rental apartment in your name? 13 MR. EDWARD: Fm sorry. Does she need to
14 A. Yes. 14 put her microphone on?
15 Q. Bite was the situation that caused 15 VIDEOGRAPHER: I can pick her up.
16 you and to part company? 16 MR. EDWARD: You can pick — Okay.
17 A. It was mutual. 17 THE VIDEOGRAPHER: That's fine.
18 Q. Was there any domestic violence involved? 18 MR. LUTT1ER: That would be a good idea.
19 A. No, sir. 19 MR. EDWARDS: Let's make sure we're
20 O• Did you have any discussions with 20 actually getting all of this.
21 at any time about this lawsuit? 21 MR. LUTTIEFt: Start over.
22 A. Yes. 22 MR. EDWARD: We don't need that.
23 Q. What discussions did you have? 23 BY MR. LUTTEER:
24 A. Well, he's saw the news and I pretty much told 24 Q. And when did you have communication with
25 him that Jeffrey F nCt in has been mol ting MP since I 25 Ms. Lan cry?
r.! ,
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1 A. We are awriates. We're friends. When did I 1 and we can confine (sic) in each other if anything. But
2 have a conversation with ha? 2 as in confining, I mean all I have to do is look in her
3 Q. Yes. Well, I don't want to limit it to a 3 eyes and'we just know the pain that we've went through.
4 conversation. When did you have communication with 4 Q. Am I going to assume correctly that the
her? 5 word you mean is confide, you confide in each other?
A. I have communication with her frequently but 6 You tell each other -
7 we don't talk about the Jeffrey Epstein case. My 7 A. No, I told you, as when I confine in her, it's
8 attorney is not her attorney. We don't choose to talk 8 as simple as we will go to a bar. We'll look at each
9 about it. 9 other in our eyes and we just realize the pain that
10 Q. When you said you are associates, what do 10 Jeffrey has caused us.
11 you mean? 11 Q. Do you have any other discussions with her
12 A. Well, I have my life and she has her life. 12 or have you had any other discussions with her in
13 Q. Well, you said that you were associates 13 more detail than that?
14 and then you said friends. But you used the term 14 A. I have know that she has an attorney and I
15 associates. 15 have mine. But other than that, we definitely don't
16 A. We are friends. 16 talk about the case because ifs negative. We already
17 Q. Do you have any kind of business 17 know what we went through.
18 relationship with her? 18 Q. Has she indicated to you whether she's
19 A. Not at all. 19 been in contact with other people that have pending
20 Q. Did you mean the word associates to mean 20 claims again Mr. Epstein?
21 something other than just merely being social 21 A. No, sir.
22 friends? 22 Q. Has she indicated to you whether or not
23 A. We are friends. 23 she has sought any professional help? By that I
24 Q. Do you have any kind of relationship with 24 mean a mental health professional, psychologist,
25 her other than simply friends? 25 psychiatrist, that thing, that type of thing?
Page 350 Page 352
1 A. We're just fiends. 1 A. No, sir.
2 Q. You have no common joint venture that 2 Q. There were some other — Ms..., is
3 you're pursuing? 3 that, is that an individual that you took to
4 A. No. 4 Mr. Epstein?
5 Q. No business that you're pursuing? 5 A. Yes, sir.
A. No. 6 Q. And on how many occasions did you take her
7 Q. Are you-all in clubs together? 7 to Mr. Epstein?
8 A. We go out sometimes. A. Around four times,
9 Q. By clubs I meant — I don't know what 9 Q. And did she go alone after that?
10 clubs women are in no, Junior League or 4-H, that 10 A. Yes, sir.
11 type of thing. I don't mean nightclubs. Are 11 Q. And did she tell you how many times she
12 you-all in any organizations together? 12 went?
13 A. No. 13 A. No, sir.
14 Q. Okay. Does — 14 Q. Has she indicated to you any intent to sue
15 A. We go out to a bar once in a blue moon. 15 you for taking her to Mr. Epstein?
16 Q. With what degree of frequency do you have 16 A. No, sir.
17 contact with her? 17 Q. Did the discussion ever come up?
18 A. I call her and tell her I love her once a 18 A. No, sir.
19 week. 19 - Q. Do you feel responsible in some part for
20 Q. Is that something unique to your 20 taking her to Mr. Epstein if she claims that she was
21 relationship with her? 21 somehow damaged as a result of going to sec him?
22 A. Yes. 22 A. No, sir.
23 Q. And what is it about your relationship 23 Q. And did you tell her when you first took
24 with her that's unique? 24 her to Mr. Epstein that nothing bad was going to
25 A. We've been fighting the Jeffrey Epstein case 25 hapeen, that she wasn'tring to be asked to do
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1 anything she didn't want to do? 1 anything at all that she didn't want to do that he
2 A. Correct. 2 insisted that she do?
3 Q. Did you tell her exactly what to expect 3 A. No. All she told me is that she was afraid of
4 when she went? 4 him and she did not want to go back.
5 A. No. S Q. And so what did you tell her after this
6 Q. And did she -- after she went the first first visit where you took her there and told her
7 time, did she indicate to you anything about the 7 that she could be as comfortable as she wanted and
visit? 8 she reported to you that she felt that she had to do
9 A. Yes. 9 whatever Mr. Epstein wanted her to do?
10 Q. What did she say? 10 A. Weil, I said why don't we go again and make
11 A. She told me she did not like it. 11 some money.
12 Q. That would be on the first visit? 12 Q. So, it was you that encouraged her
13 A. Yet 13 notwithstanding whatever reservations she told you
14 Q. Did she say Mr. Epstein did anything or 14 to go back to Mr. Epstein?
15 forced her to do anything that she didn't want to 15 A. Yes.
16 do? 16 Q. And you told her let's do that because you
17 A. Mr. Epstein always told us don't tell anybody. 17 wanted to make money; is that correct?
18 He just wanted us to find girls. So, whatever 18 A. Yes.
19 transpired between her and Mr. Jeffrey Epstein, i 19 Q. And after the second visit, did Ms. •
20 don't -- I'm not sure. 20 tell you that, anything about her visit with
21 MR. LUTHER: Move to strike as not being 21. Mr. Epstein?
22 responsive to the question. My question was, 22 A. She told me the same thing. She was very
23 if you will read back what my question was to 23 quiet about it. She said I do not want to go back.
24 the witness. 24 Q. And notwithstanding that comment did you
25 (Tbe requested portion of the record was 25 take her back a third time?
Faye 3 Page 356
1 read by the reporter.) 1 A. Yes.
2 THE WITNESS: Yes. 2 Q. And what did you tell her after she told
3 BY MR. LUTTIER: 3 you she didn't want to go back?
4 Q. What did she tell you? 4 A. I was stubborn and I said let's go back, and
5 A. She said that she felt very obligated to do 5 please make some more money.
6 what Mr. Jeffrey Epstein had asked her to do. 6 Q. So, would it be a fair statement to say
7 Q. And what did she say Mr. Epstein asked her 7 that you coerced her into going back?
8 to do? 8 A. Yes.
9 A. Take off her clothes. 9 Q. Now, why would you coerce a friend of
10 Q. And you had told her before she went that 1.0 yours to go back?
11 that was going to be requested of her, right? 11. A. Well, when you're -- at that time I was 14.
12 A. Brom what I remember, I told her that, that 12 And when you're 14 and you're poor, a young lady is
13 she would be in a room and we were going to massage his 13 going to do anything for money especially when you're
14 thighs. And then oncel left the room you can be as 14 intimidated by a man who lives in an island that was
15 comfortable as you want to be with him. 15 highly, highly known of. And i was very intimidated by
16 Q. And did she say anything other than that 16 Jeffrey, and he always wanted me to bring girls. And he
17 occurred? 17 told me, make sure you have a girl for me. So, at that
18 A. Excuse me? 18 time, I would only, at that specific time i would only
19 Q. Did she say anything other than that 19 have
20 occurred? 20 Q. Had you been brought up with any kind of
21 A. She said she wasn't comfortable. 21 moral upbringing from your parents?
22 Q. And did she say that she told Mr. Epstein 22 A. Yes.
23 that? 23 Q. And had you been taught as a, as a child
24 A. No, she was scared of him. 24 from as far back as you can remember not to do
25 Q. She indicate that she told Mr. Epstein 25 things that were wrong?
%el
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1 A. Yes. 1 Eisenberg at the statement representing you,
2 Q. And you discarded your upbringing and 2 correct?
3 decided in order to make money you would tell your, 3 A. Yes.
4 one of your good friends that notwithstanding her 4 Q. Okay. And did you tell the FBI what you
5 reservations about going back to Mr. Epstein that 5 just told me about the conversations you had with
b you wanted her to do that; is that correct? 6 el ?
7 A. Yes. 7 A. No.
8 Q. Other than Ms. E telling you that she 8 Q. In fact what you told the FBI was exactly
9 felt that she was obligated to do what Mr. Epstein 9 the opposite, was it not?
10 wanted her to do, did she tell you anything about, 10 A. Correct.
11 anything else about her conversations or 11 Q. Now, there are a number of other people
12 interactions with Mr. Epstein at any time? 12 who in the first deposition you said you had contact
13 A. She told me that if Jeffrey told her if she 13 with in the past. So, I want to make sure we
14 was to tell anybody, she would be in trouble. 14 haven't missed anybody with respect to my question
15 Q. Did she tell you anything else? 15 about communications with them since September 24th
16 A. No. 16 of '09. There was a lady you referred to in your
17 Q. Now, at some point in time before you 17 previous deposition by the name of At the
18 filed this lawsuit, the FBI came to visit with you? 18 time of your prior deposition you sae you
19 A. Yes. 19 know her last name. Do you now know her last name?
20 Q. Is that correct? 20 A. No, sir.
21 A. Yes. 21 Q. Say what?
22 Q. And they took a sworn statement from you, 22 A. No, sir.
23 correct? 23 Q. Does the name Msound familiar to
24 A. At what time? 24 you?
25 Q. They took a sworn statement sometime 25 A. No, sir.
Page 358 Page 360
1 before you filed this lawsuit? 1 Q Have you had any communications with this
2 A. Yes. 2 lady since your September 24th, '09,
3 Q And you were represented by a lawyer at 3 deposition
4 that sworn statement; is that right? 4 A. No, sir.
5. MR. EDWARDS: Object, I object to the 5 Q Have you had any communications with a
6 form. And I know that it's not your intention 6 lady by the name of Jane Doe II since your September
7 to rehash the entire first deposition, but I 7 24th, '09, deposition?
8 think this area was covered. So, to the extent 8 A. No, sir.
9 that it wasn't, then obviously the inquiry can 9 Q. Have you had any communications with a
10 proceed, but we're not going to rehash the 10 lady by the name of Jane Doe since your September
11 entire event as it happened in the first 11 24th, 2009, deposition?
12 deposition. 12 A. No, sir.
13 MR. LUTHER: I have no intention to. 13 Q. On your last deposition, you indicated to
14 BY MR. LUTHER: 14 us that at some point in tune Ms. Jane Doe,'
15 Q. You were represented by a lawyer at that 15 believe, had watched your son for you on some
16 time, correct? 16 occasion?
17 A. On Jeffreys behalf? 17 A. Yes. About two occasions.
18 Q. No, on your behalf. There was a lawyer 18 Q. Okay. Other than those two occasions that
19 there who represented to the FBI that he was your 19 you've described in the previous deposition, has
20 lawyer, is that right? 20 Ms. Jane Doe ever watched your son since then or on
21. MR. EDWARDS: Object to the form. 21 any other occasion?
22 THE WITNESS: I am not understanding this, 22 A. No, sir.
23 sir. • 23 Q Since your September 24th, '09, deposition
24 BY MR. LIMITER: 24 have you ever had anybody else watch your son or has
25 Q. There was a fellow by the name of James 25 he always been with you since then?
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1 A. I have a,1 have a babysitter. 1 A. Yes, or at night as well.
2 Q. And who is your babysitter? 2 Q. Whose shows do you sell? What line of
3 A. 3 shoes? . .
4 A. I sell BCBG, Jessica Simpson. Coach. I can
5 pretty much get any shoe.
6 6 Q. And where do you get the shoes?
7 A. Igo to Macy's. Igo to the clearance rack.
8. I buy them for really cheap, and 1 sell them for what
9 A. I'm not really sure how to spell -- 9 they are originally.
10 Q. Where — 10 Q. So, you would go into a Macy's, if there
11 A. — her 11 was a clearance and buy a half a dozen pairs of
12 Q. WherenaZ4IMI reside? 12 shoes?
13 A. She resides in the, in the acreage. I'm not 13 A. Yes. •
14 positive what the address is. 14 Q. Without knowing what anybody's size was?
15 Q. With what degree of frequency since 15 A. Correct.
16 September 24th, '09, have you utilized her services 16 Q. In other words you don't get somebody's
17 to watch your son? 17 order first and go fill the order?
18 A. Very frequently. Ever since December, I mean 18 A. I could do that but I really don't — I would
19 January 1st, 2010, she watches my son regularly. 19 rather go there and buy a bulk of shoes with whatever
20 Q. Is there like certain days of the week she 20 size. And if someone is interested in a nail salon, you
21 automatically watches him? 21 know, and if ifs their size, then they'll buy it
22 A. No. 22 Q. When did you first start selling these
23 Q. And, and why -- is the frequency with 23 shoes?
24 which she watches your son since January of 2010 24 A. January I st, 2010.
zs greater than the frequency with which you had people 25 Q. And did somebody introduce you to this
Page 362 Page 364
1 watch your son prior to that date? 1 business?
2 A. Excuse me? Can you — 2 A. No.
3 Q. Why is she watching your son frequently 3 Q. This is something you came up with on your
4 since January 10? 4 own?
5 A. So I can work. 5 A. Yes.
6 Q. Okay. Where are you working? 6 • Q. Okay. Who do you sell lingerie for?
7 A. I sell Mary Kay, shoes, lingerie, and clothes. 7 A. I go to different areas. I go to, I will go
8 Q. Mary Kay shoes? 8 to strip clubs and sell lingerie if they want it. My
9 A. Lingerie and clothes. 9' girlfriends. I sell lingerie to. Valentine's is coming
10 Q. Lingerie and what else? 10 up. I will be selling a lot of lingerie soon.
11 A. And clothes. 11. Q. Who do you get the lingerie from?
12 Q. Is that, is that all of that Mary ICay 12 A. Igo to local adult stores and I go to the
13 items; that is Mary Kay has a line of shoes, or are 13 clearance and I buy them in bulk, and then I sell them
14 you saying — 14 for the original or more price.
15 A. No. 15 Q So and when do you go to these strip
16 Q. — that you sell Mary Kay cosmetics, plus 16 clubs, during the day or at night?
17 you sell shoes, plus you sell lingerie, plus you • 17 A. Both.
18 sell clothes? 18 Q. And what do you do at these strip clubs?
19 A. Yes. 19 MR. EDWARDS: Object to the form You tan
20 Q. All right And do you — what hours do 20 EMSWer.
23. you work? 21 THE WITNESS: Yeah, I walk In with my
22 A. Well, 1 just, it's on my own hours. I will go 22 duffel bag MI oldie items I like to sell,
23' to tanning salons to see if anybody wants to buy. I 23 and the women get to choose what they wait to
24 will go to nail salons. .24. buy
25 Q. Is this all during the day? 25.
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1 BY MR.. LUITIER: 1 Q. So, what you are telling the ladies and
2 Q. Do you dance at any of these strip clubs? 2 gentlemen of the jury is somebody pays you three to
3 A. No, sir. 3 $500 an hour just to be in your company and not to
4 ' Q. Have you danced anywhere since September 4 have any sex with you?
5 24th, 2009? 5 MR.. EDWARDS: Object to the fonn.
6 A. No, sir. 6 BY MR. LUTTIER:
7 Q. Have you worked in any adult establishment 7 Q. Is that right?
8 of any kind or nature since September 24th, 2009? 8 MR. EDWARDS: And just so that the record
9 A. Not in a strip joint, no. 9 Is clear, the wage claim, the loss wages and
10 Q. Okay. Well, have you worked in any other 10 loss of earning capacity has been withdrawn in
11 kind of adult establishment other than a strip joint 11 the case.
12 since September 24th, '09? 12 You can answer the question, if you
13 A. Yes. 13 understand the question.
14 Q. Where have you worked? 14 BY MR. LUTTIER:
15 A. I have worked for my private clientele. 15 Q. Is that right.
1.6 Q. What do you mean by "private clientele"? 16 A. What was the question?
17 A. I have worked, I have been company to a few 17 Q. So you're telling the ladies and gentlemen
18 men that I have met ever since the last deposition, and 18 of the jury that men pay you three to $500 an hour
19 I provide company for than. 19 just for your company but you have no sex with them;
20 Q. The last time you told us you had worked 20 is that correct?
21 for an escort service. Do you recall that? 21 MR. EDWARDS: Object to the form.
22 A. Correct 22 111E WITNESS: Correct.
23 Q. Is this in essence the same thing you're 23 BY MR. LUTHER:
24 still doing? 24 Q. Or is sex an additional charge?
25 A. No. 25 A. No, I don't have sex with them.
Page 366 Page 368
1 Q. Are you working for an escort service now? 1 Q. Have you ever — or when did you start
2 A. No. 2 this little escort service that you're describing
3 Q. Have you been working for an escort 3 now?
4 service since September 24th, 2009? 4 A. Well, I don't know what your definition of
5 A. No, sir. 5 escort is. It's pretty much I offer my company to got
6 Q. Do you advertise your services somehow? 6 paid. January 5th, 2010.
7 A. No, sir. 71 Q. And how did you fix on the date
8 Q. So, how do you — how do these people know 8 January 5th?
9 to retain your services? 9 A. I had met a gentleman named Bobby in CityPlace
10 A. Word of mouth. 10 and we sat down for a drink and we just started talking.
1 Q Okay. And how do they get word of mouth? 11 Q. Had you gone there to meet him?
12 A. I have one client, Bobby, and he has referred 12 A. No, I just went there by myself. And I
13 me to three other clients. 13 just —
14 Q. And what's the difference between what you 14 Q. Did you meet him in an establishment at
15 are doling with these clients and what you did with 15 CityPlaoe?
16 the escort service? 16 A. I met him at Carousel.
17 A. Well, the difference is is that I don't 17 Q. Okay. That's a restaurant and a bar
18 perform any sexual acts. It's pretty much just I am 18 there?
19 company if — they pay me for my company. 19 A. It's a restaurant, correct.
20 Q. Well, how much do they pay you for your 20 Q. Okay. Is that Can Can --
21 company? 21 A. Can Can Carousel (sic).
22 A. It ranges anyway, any any price is from 300 22 Q. Motive or motif?
23 to 500. 23 A. Can Can Carousel.
24 g 300 to 500 what? 24 Q. Right The waitresses are in cancan
25 A. An hour. 25 outfits and dance on the tables or something like
9 (Pages 365 to 368)
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
EFTA01108816
Page 369 Page 371
1 that? 1 males approximately your age would ask you out to a
2 A. Yes. 2 movie or something like that on a date. Has that
3 Q. And were, were you there -- why were you 3 happened to you?
4 there? 4 A. Yes. With these men, yes.
5 A. I was just — Igo out by myself sometimes 5 Q. So, what these people -- you consider
6 just to recuperate and have a nice drink and a nice 6 these people dates; is that what you're telling me?
7 dinner by myself. I am single. 7 A. Yes, we go out to the movies. We go out to
8 Q. So, were you there for dinner or were you 8 eat dinner.
9 there for something else? 9 Q. How many dates did you have as a youth
10 A. I was there fora drink. 10 where people paid you three to 5500 an hour —
11 Q. So you went to the bar? 11 A. Sir --
12 A. Yes. 12 Q just to have the opporttmity to date
13 Q. And this fellow happened to be at the bar? 13 you?
14 A. Yes. 14 A. Ever since Jeffrey Epstein --
15 Q. And it wasn't, it wasn't prearranged. He 15 MIL EDWARDS: Objec
DataSet-10
Unknown
6 pages
From: "Matthew I. Menchel"
To: 'Jeffrey Epstein'
Subject: RE: Re:
Date: Tue, 01 Feb 2011 14:34:39 +0000
Unfortunately, no I've got a deposition that I'm taking in Florida on the 14th. I will be in New York on the 9th (which I think
I mentioned to you) but I am giving a lecture during lunchtime and then flying home that evening. I could meet you for a
late lunch on that day. Otherwise, I probably won't be back until around mid-March.
Matthew I. Menchel
KOBRE & KIM LLP
www.kobrekim.com
New York I London I Hong Kong I Washington DC I Miami
From: Jeffrey Epstein [mallto:jeevacation@gmall.com]
Sent: Tuesday, February 01, 2011 9:28 AM
To: Matthew I. Menchel
Subject: Re: Re:
can you do florida the 13 th or 14th?
On Tue, Feb 1, 2011 at 9:27 AM, Matthew I. Menchel < > wrote:
Did you meant to write something? There is nothing in the response.
Matthew 1. Menchel
KOBRE & KIM LLP
www.kobrelcim.com
New Vol* I London I Hong Kong I Washington DC I Miami
From: Jeffrey Epstein [mailto:jeevacation®gmail.com]
Sent: Tuesday, February 01, 2011 9:27 AM
To: Matthew I. Menchel
Subject: Re: Re:
On Tue, Feb 1, 2011 at 9:22 AM, Matthew I. Menchel < > wrote:
Jeffrey,
My flight to New York just got cancelled along with my Court appearance so I won't be in New York tomorrow.
My apologies but obviously out of my control. I'll let you know next time I'm headed up that way or if you are
in Florida we could always meet down here as well.
EFTA00697115
Best,
Matt
Matthew I. Menchel
KOBRE & KIM LLP
www.kobrekim.com
New York I London I Hong Kong I Washington DC I Miami
Original Message
From: jeffrey epstein [mailto:jeevacation@gmail.com]
Sent: Sunday, January 23, 2011 12:22 PM
To: Matthew I. Menchel
Subject: Re: Re:
Lunch , lord MANDELSON will join if ok with you
Sony for all the typos .Sent from my iPhone
On Jan 23, 2011, at 5:01 PM, "Matthew I. Menchel" < > wrote:
> Lunch or Dinner on the 2nd?
> Matthew I. Menchel
> KOBRE & KIM LLP
> www.kobrekim.com
> New York I London I Hong Kong I Washington DC I Miami
> From: Jeffrey Epstein
> >
> Date: Sun, 23 Jan 2011 16:09:10 +0100
> To: Matthew Menchel
cmailto:
> Subject: Re: RE: Re:
> Any chance the week before? You would join interesting people?
> Sony for all the typos .Sent from my iPhone
> On Jan 23, 2011, at 4:00 PM, "Matthew I. Menchel"
mailto >> wrote:
> How does a late lunch on the 8th work for you? Have to give a presentation during lunchtime but could meet
with you afterwards.
> Matthew I. Menchel
EFTA00697116
> KOBRE & KIM LLP
> www.kobrekim.com
> New York I London I Hong Kong I Washington DC I Miami
> From: Jeffrey Epstein [mailto:jeevacation@gmail.com]
> Sent: Wednesday, January 19, 2011 12:32 PM
> To: Matthew I. Menchel
> Subject: Re:
> sometine that week . I thought you would come to dinner with woody allen this week, but i will wait to see
you that week.
> On Wed Jan 19, 2011 at 7:29 AM, Matthew I. Menchel
«mailto: mails
> wrote:
> In London doing an ICC arbitration. Should be back in NY February 2. Will you be around?
> Matthew I. Menchel
> KOBRE & KIM LLP
> www.kobrekim.com
> New York I London I Hong Kong I Washington, DC I Miami
> From: Jeffrey Epstein
> [mailto:‹mailto:jeevacation@gmail.com>jea@gmail.conailto:jee
> vacation@gmail.com>.]
> Sent: Wednesday, January 19, 2011 06:50 AM
> To: Matthew I. Menchel
> Subject:
> are you in town
> --
>
> 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
> Jeffrey Epstein 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.conailto:jeevacation®gmail.com>, and destroy this
> communication and all copies thereof, including all attachments.
> copyright -all rights reserved
> This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or
confidential information. If the reader of this message is not the intended recipient(s), or the employee or agent
EFTA00697117
responsible for delivering the message to the intended recipient(s), you are hereby notified that any
dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this
message in error, please notify the sender immediately and delete this e-mail message and any attachments from
your computer without retaining a copy.
> IRS Circular 230 disclosure: Any tax advice contained in this
> communication (including any attachments or enclosures) was not
> intended or written to be used, and cannot be used, for the purpose of
> (i) avoiding penalties under the Internal Revenue Code or (ii)
> promoting, marketing or recommending to another party any transaction
> or matter addressed in this communication. (The foregoing disclaimer
> has been affixed pursuant to U.S. Treasury regulations governing tax
> practitioners.)
> --
>
> 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
> Jeffrey Epstein 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.conailto:jeevacation@gmail.com>, and destroy this
> communication and all copies thereof, including all attachments.
> copyright -all rights reserved
> This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or
confidential information. If the reader of this message is not the intended recipient(s), or the employee or agent
responsible for delivering the message to the intended recipient(s), you are hereby notified that any
dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this
message in error, please notify the sender immediately and delete this e-mail message and any attachments from
your computer without retaining a copy.
> IRS Circular 230 disclosure: Any tax advice contained in this
> communication (including any attachments or enclosures) was not
> intended or written to be used, and cannot be used, for the purpose of
> (i) avoiding penalties under the Internal Revenue Code or (ii)
> promoting, marketing or recommending to another party any transaction
> or matter addressed in this communication. (The foregoing disclaimer
> has been affixed pursuant to U.S. Treasury regulations governing tax
> practitioners.)
> This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or
EFTA00697118
confidential information. If the reader of this message is not the intended recipient(s), or the employee or agent
responsible for delivering the message to the intended recipient(s), you are hereby notified that any
dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this
message in error, please notify the sender immediately and delete this e-mail message and any attachments from
your computer without retaining a copy.
> IRS Circular 230 disclosure: Any tax advice contained in this
> communication (including any attachments or enclosures) was not
> intended or written to be used, and cannot be used, for the purpose of
> (i) avoiding penalties under the Internal Revenue Code or (ii)
> promoting, marketing or recommending to another party any transaction
> or matter addressed in this communication. (The foregoing disclaimer
> has been affixed pursuant to U.S. Treasury regulations governing tax
> practitioners.)
This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged and/or
confidential information. If the reader of this message is not the intended recipient(s), or the employee or agent
responsible for delivering the message to the intended recipient(s), you are hereby notified that any
dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this
message in error, please notify the sender immediately and delete this e-mail message and any attachments from
your computer without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication (including any attachments or
enclosures) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties
under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction
or matter addressed in this communication. (The foregoing disclaimer has been affixed pursuant to U.S. Treasury
regulations governing tax practitioners.)
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
Jeffrey Epstein
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
This e-mail message is from Kobre S Kim LLP, a law firm, and may contain legally
privileged and/or confidential information. If the reader of this message is not the
intended recipient(s), or the employee or agent responsible for delivering the message to
the intended recipient(s), you are hereby notified that any dissemination, distribution or
copying of this e-mail message is strictly prohibited. If you have received this message
in error, please notify the sender immediately and delete this e-mail message and any
attachments from your computer without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication (including any
attachments or enclosures) was not intended or written to be used, and cannot be used, for
EFTA00697119
the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting,
marketing or recommending to another party any transaction or matter addressed in this
communication. (The foregoing disclaimer has been affixed pursuant to U.S. Treasury
regulations governing tax practitioners.)
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
Jeffrey Epstein
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 jeevacatio and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
This e-mail message is from Kobre S Kim LLP, a law firm, and may contain legally
privileged and/or confidential information. If the reader of this message is not the
intended recipient(s), or the employee or agent responsible for delivering the message to
the intended recipient(s), you are hereby notified that any dissemination, distribution or
copying of this e-mail message is strictly prohibited. If you have received this message
in error, please notify the sender immediately and delete this e-mail message and any
attachments from your computer without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication (including any
attachments or enclosures) was not intended or written to be used, and cannot be used, for
the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting,
marketing or recommending to another party any transaction or matter addressed in this
communication. (The foregoing disclaimer has been affixed pursuant to U.S. Treasury
regulations governing tax practitioners.)
EFTA00697120
DataSet-10
Unknown
1 pages
From: Faith Kates
Sent: Thursday, Marc , :
To: Jeffrey Epstein
Gma today spoke about the queen speaking to andrew about=your relationship showed pics looks like from a deposition
maybe blue polo=shirt you were hooked to a mike
Call me later
xoxo
NOTE:This message including =ny attachments contains information, some or all of which, may be propriet=ry or legally
privileged. It is for the intended recipient only. If you ha=e received this message by error, please notify us immediately
and destroy the related message. You, the recipient,=are obligated to maintain it in a safe, secure, and confidential
manner. U=authorized re-disclosure or failure to maintain confidentiality could subj=ct you to penalties described in
Federal and State law. Next Management, LLC and any affiliate companies ar= not responsible for errors or omissions in
this message or any attachment=.
1
EFTA_R1_00155029
EFTA01807061
DataSet-10
Unknown
1 pages
From: ==. >
To: Jefffrey Epstein , darren indyke
Subject: Deposition Wed Nov 28?
Date: Fri, 23 Nov 2018 19:58:57 +0000
Do we know if I go for a deposition on Wed Nov 28? I was asked to set this date aside but
have not heard anything in awhile.
Sent from my iPhone
EFTA00485075
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
EFTA00611586
DataSet-10
Unknown
38 pages
0 9 — Igo
Condensed Transcript
• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
Plaintiff,
vs. CASE No.
502008CA028051XXXXMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
• VOLUME I
October, 20. 2009
10:10 a.m.
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
• Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, Ft. 33410
www.esqulresoluttons.com
3501.172-001
CONFIDENTIAL Page I of 38
EFTA_00070807
EFTA01247530
•
•
•
3501.172-001
CONFIDENTIAL Page 2 of 38
EFTA_00070808
EFTA01247531
- Volume I October 20, 2009
1 3
IR na chicory cceer OF TIM FIFTRI26111 JOICTAL CIRCUIT 1 APPEARANCES'
111 AND FOR PAlM SIAM CCM', FLORIDA
• Plaintiff,
CIVIL DIVISION
CASK No.5132COSCAOTSCD/XXX/30 AS
2
3
4
On behalf of the Defoxlant:
ROBERT 0. CRITTON, JR.. ESQUIRE
BURIMN CRITTON LIMIER & COLEMAN. LLP
303 Banyan Boulevard. Suite 400
JRFIRIT errotte. West Riatairda 33401
Phoe:
Defendant. 6
7 On behalf of PORNO :
A
DITPGItlal
vel)P1R=-
9
111044411. October. 20. 2009
10110 - 1,10 p.a. 10
11
12 00 'WS
13
%sported Sy: 14
Teresa IabaIon, RPR. PPR
Notary Public. Stab of Florida 15
Neat Palt leach Office Job
16
17 On behalf or Wanda
19
20
21 On behalf M PMaLMt in reWmd Cabe No 08-80811
22
23
24
35
2 4
1 UNITED STATES DISTRICT COURT 1 • •
• 2
3
4
SOUTHERN DISTRICT OF FLORIDA
CASE No.06-CV-60119-CIV•MARRAMOHNSON
2
3
WITNESS
INDEX
' "
DIRECT CROSS REDIRECT RECROSS
PIIe I,
6
1 JEFFREY EPSTEIN,
Deist 7
9 Related cases 0 BY MRIn i5 190
08-80232, 08-80380. 93-8038I. 08-80904. 9 BY LEL 135 208
10 08-80993. WSW 1. 004/0893. 0943469. :o BY ma= 156
09-80591. 0940656. memex.09-elos2
II 11 BY MR. 173
12
12
DEPOSITION OF
VOLUME I 13
14 II EXHIBITS
Tuesday. Ocfcbts 20. 2009
15 1010 - 3:33 p.m as
16 16
11 11 NUMBER DESCRIPTION PAGE
IS DEFENDANTS EX. I COPIES, COMPOSITE PHOTOGRAPHS 103
1
19 19 DEFENDANTS EX. 2 COMPO9TE FICNE MESSAGE BOOK 147
20 20 DEFENDANTS EX 3 COPY OF PHOTOGRAPH 162
21 Reported By:
TINOS. Whalen. APR, FPR 21
22 WINO PROC. STIDO of Fbrkla 22
West Palm Beech Office Job is116991 23
23 Phone: 800.330.6952
561 659 4155 24
24 21
25
• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutIons.com
CONFIDENTIAL 3501.172-001
Page 3 of 38
EFTA_00070809
EFTA01247532
IMIIM MID - Volume October 20, 2009
5 7
1 PROCEEDINGS 1 0 How long have you been employed by
2
3
4
Deposition taken before Teresa Whalen:
Registered Professional Reporter, Florida
Professional Reporter, and Notary Public In and for
2
3
4
Mr. Epstein?
A It will be live years this November 17th.
0 So you started November 17th, 2004?
A Yes. sir.
•
6 the State of Florida at Large, in the above cause. 6 0 And how did you get hired by Mr. Epstein?
- - 7 A Through an agency.
8 Thereupon, 8 0 What agency?
9
10
MIS)
having been first duly sworn or affirmed. was examined
9 A It's Regal Domestics.
to 0 And what was your position that you were tired
11 and testified as knows: 11 by Mr. Epstein la?
12 THE WITNESS: I do. 12 A Housekeeper-
13 DIRECT EXAMINATION 13 0 We've taken the deposition of another witness
14 MR Does anyone want to put on the 14 in this case, Alfredo Rodriguez. Aro you familiar with
15 record what case INS is bang taken in? I noticed 15 that name?
16 it ire. versus Epstein. I don't know if anybody 16 A Yes.
17 cares to say who your clients me, what the case 17 0 And that person. I believe he represented that
18 style is or hi else for when she types it up. 18 he was also maybe a house manager. IS that correct?
19 MR I don't have a problem with 19 A Correct.
20 that. Are we doing initials? 20 0 Would he have been, at some point in time,
21 MR Yeah. Initials. 21 your boss or your superior?
22 MRS Okay. 22 A Yes.
23 BY MR. 23 0 That's somebody who you answered to,
24 0 All right. Will you state your name for the 24 Alfredo Rodriguez?
25 record. 25 A (Nodang head). Sometimes
6
1 A
Ma
•
1 You have to say yes or no. you
2 2 card nod your hoed.
3 3 BY I.E.
4 4 0 Yes?
5 5 A Yes.
6 6 MR. CRITTON: No. no. Site said SOMNIMOS.
7 7 then yeingaijaper Muth.
8 MR. . laden put anything in her
9 9 mouth. I don't want the record -
10 10 MR. CRITTON: Let me take It back. You said
11 11 yes. but she started to say something before she
12 12 vas Interrupted.
13 13 BYMi
14 14 O That's line. You cal answer the question.
15 15 then well irettua On the deposition.
16 16 : Did you want to explain that
17 17 further?
18 18 THE WITNESS: Because we wore supposed towed(
19 O Have you ever lived at Jeffrey Epstein's 19 together. Nit he was bossy. he was bossy.
20 location of 358 El Brillo Way? 20 BY I.E.
21 A No, sir. 21 0 Okay. Have you ever had your deposition taken
22 0 Whore are you currently employed? 22 before Ike this?
23 A Mr. Epstein. 23 A No.
24 0 And what address do you report to work? 24 0 All right. Well, there is one oourt repater,
25 A 358 El Brae Way. 25 n very easy In casual conversation to nod your
• Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
•
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
vnvw.esquiresolutions.com
3501.172-001
CONFIDENTIAL Page 4 of 38
EFTA 00070810
EFTA01247533
- Volume I October 20, 2009
9 11
I head or shake your head, and she can't take that down. 1 that it's clean and appropriately. what's this...
• 2
3
4
5
A All right
O It's also very easy to say uh-huh or huh-uh,
but it kind of looks the same on paper, so you can't do
that either. I'm going to wait until you finish your
2
3
4
O And as I understand this property, there is a
main house and then there's also a staff house on the
property. is that right?
A Yeast
6 answer, and you have to wait until I finish my question, 6 O And when the guests would come over, would you
7 because if we talk over one another, then the court 7 stay in the main house. or would you go to the staff
8 reporter can't get it down. 8 house?
9 A Okay. Yes, sir. 9 Can we get a time frame to the
10 O All right. So if you don't understand the 10 question?
n questiOn, sell me you don't understand and I'll try to 11 BY MR.-
12 ask a better question. 12 O Over the last five yews while you worked
13 A Yes. 13 there.
14 O Okay. So you were hired in November ol 2004 14 A I usually stay in the staff house and do the
15 to be the housekeeper for Mr. Epstein? 15 laundry, then I go to the kitchen and then tidy the
16 A Yes. 16 kitchen.
17 0 And when you were hired, who exactly hired 17 O You were hired in November of 2004. and what
10 you, who — let me strike that. 18 were your hours that you worked there back in November
19 When you were hired to be the housekeeper for 19 of 2004 when you were hired?
20 Mr. Epstein, who did you interview with? 20 A Eight to five.
21 A Ms. Maxwell. 21 O How many days a week?
22 O Is that Ghislaine Maxwell or just 22 A Depends.
23 Leine Maxwell? 23 O Flow would the schedule be relayed to you?
24 A Ghislaine Maxwell. 24 A When Mr. Epstein is there, then I'm supposed
25 O And where did the interview take place? 25 to report, but usually it's live days a week.
10 12
• 1 A At 358 El Belo Way. 1 O So am I correct in understanding that there
2 O And what did Ms. Maxwell and you speak about 2 was one schedule when Mr. Epstein was in town, and the
3 prior to your being hired as the housekeeper'? 3 schedule may be a little bit different it Mr. Epstein
4 A My duties. 4 was out of town?
O And what did she tell you your duties would 5 A Yes, sir.
6 be? 6 O All right. Tell me the differences when
7 A To tidy, to make beds, do laundry 7 Mr. Epstein Is in town versus when Mr. Epstein was not
8 O Did she tell you what would take ptace in the in town.
9 house on a day-to-day basis? 9 A If he stays like three or four days, then I'm
10 A No. 10 supposed to be there. and then the house is to be
11 O So going into that position, you had no idea 11 cleaned. And then when they do not come, then I can
12 who the guests would be or who the people Coming in the 12 either go there, or I'm gven free days off.
13 house would be, or what would generally go on? 13 Cr Three days off?
14 A Can you simplify the question? 14 A No. A free day.
15 O Sure. When you talked about with 15 o Oh. okay. But typically back in 2004 when you
16 Ghlslaine Maxwell at this interview, your duties being 16 were hired, you worked an average of about five days a
17 you would make the bed and tidy up, did she also tell 17 week; is that correct?
103 you that there would be a lot of guests, there would be 18 A Yes.
19 a few guests, did she talk to you about that at all? 19 o All right. And I guess by the way that you're
20 A She mentioned Petri there are guests, we 20 explaining it, of Mr. Epstein was in town for a longer
21 have to, like, you know, prepare the room, and, what's 2L period of time, you may work more than five days. and if
22 this. attend to the guests. 22 Mr. Epstein was not in town, you may work less than five
23 O And what did you understand that to mean that 23 days?
24 you have to attend to the guests? 24 A YOS.
25 A You have to prepare the room and see to it 25 o Okay. Did you ever talk to Mr. Epstein prior
Toll Free: 866.709.8777
Facsimile: 561.394.2621
• 0
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.eSqUiresOlutiOns.com
3501.172-001
CONFIDENTIAL Page 5 of 38
EFTYL00070811
EFTA01247534
- Volume I October 20, 2009
13 15
1
•
1 to being hired? 0 Did she tea what you would be paid at that
2 A No. sir. 2 time?
3 O Where did this meeting, within the house where 3 A Not yet.
4 did the meeting with Ghislaine Maxwell take place? 4 0 Did you show up that Saturday? I guess that's
A In the living room. 5 November 17th of 2004?
6 O Aside from telling you that you were going to 6 A No, that's not.
7 be required to make the beds and just generally tidy up, 7 0 No. Was it prior to November 17th of 2004. or
did she specify anything else that you would be required 8 after?
9 to do? 9 A After.
10 A No. 10 0 Okay. The interview that you first went to
11 11 was November 17th. 2004 with Ms. Maxwell; is that the
12 12 date that you gave us?
13 13 A I cannot remember.
14 14 0 The only reason I'm using that date is I
15 15 believe the question I asked was when did you start
16 16 working for Mr. Epstein, and I thought the date that you
17 17 gave me was November 17th. 2004.
18 18 A Yes.
39 19 0 Okay. And in the course of this whole thing.
20 20 it sounds like you interviewed with Ghislaine Maxwell.
21 21 there were other interviewees, you received a call and
22 22 you were asked to try out on a Saturday?
23 23 A Yes.
24 O And when you went to the interview. Obviously 24 0 And where does that Saturday fall in related
25 youtre going to this very big house and you talked to 25 to November 17th, 2004?
14 16
1
2
3
4
Ghislaine Maxwell. right?
A Yes.
0 And did you decide right then that you Med
this and that you were going to change professions and
2
3
4
A When I accepted the fob offer.
0 Okay. And did they tel you at that time sten
you accepted the job offer how much you WOW Going to he
paid?
•
5 you were going to be his housekeeper? s A Yes.
6 A No. 6 0 What was that?
7 0 Okay. Then walk me through that, how did you 7 A It was 32.000 per annum.
8 go about eventually accepting the position? 0 And haS your salary increased ovor time?
9 A I didn't expect to be hired. because there 9 A Yes. sir.
10 were other interviewers (sic). interview people that 10 0 And can you walk us through the increments of
11 were to be interviewed. 11 increase n your salary?
12 0 Okay. 12 A It was PronliSed yearly increase'
13 A And then I receive a call from Ms. Maxwell it 13 0 By whom?
14 I like. I can do a try-out. 14 A Ms. Maxwell
15 0 Okay. Did the tell you how long this try-out 15 0 Was that at the lime whon you wore
16 period would last? 16 interviewed, or look the job?
17 A No. 17 A Yes. sir.
18 0 And what did you tell her when sho made that 18 0 Did the promise you what your yearly Increase
19 offer for you to try out? 19 would be?
20 A I told her that I am still taking care of this 20 A No.
21 patient, so she said if you like, you can come Saturday 21 0 And have you received a yearly increase every
22 and try it. 22 year?
23 0 Okay. And what did you tell her, did you 23 A Idid.
24 accept that? 24 0 And what has that yearly increase been?
25 A Yes,Idid. 25 A Up to 42.
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
0
Suite 600
ESQUIRE
uMtGW.Cw
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquireSolutions.com
3501.172-001
CONFIDENTIAL Page 6 of 38
EFTA_00070812
EFTA01247535
- Volume I October 20, 2009
17 19
1 0 Today? 1 O Okay. So legs talk about lhat. Back in
• 2
3
S
A Yes.
0 So you're making $42,000 today. and that's the
meet that you've made over the five-year period you've
worked for Mr. Epstein?
2
3
4
5
November o12004, you were to working 8:03 a.m. to
5:00 p.m. And when Cod that schedule change from 8:00
5:00?
A When? When the house was renovated.
6 A Yes, sir. 6 O When was that, do you remember the year?
7 O At the lime when you -- when we took 7 A 2006.
8 Alfredo Rodriguez's deposition, he described you as a a O Okay.
9 very religious Catholic woman. Does that accurately 9 MR. CRITTON: I'm sorry. '06?
10 describe you? 10 THE WITNESS: '06.
11 MR. CRITTON: Let me just object to the form. 11 BY MR. -
12 You can answer the question If 12 O So from November 2004 through '06, I'm correct
13 you understood it. 13 in presumi ng that your schedule was an average cativo
14 THE WITNESS: I am a Catholic and I go to 14 days a week from 8:00 a.m. to 5:00 p.m.?
15 mass. 15 A At that time I go nine o'clock. I go to the
16 BY MR. 16 house at nine o'clock.
17 O Is that something you go to regularly? 17 O Starting in 2006?
18 A III have time. I go regularly. 18 A Yes.
19 O When do you normally go to mass? 19 O So when your schedule changed from 8:00 ti
20 A Sunday masses and weekdays. 20 5:00. in 2006 you started going to the house,
21 o How many weekdays? 21 Jeffrey Epstein's house, at nine o'clock?
22 A 111 can, every day. 22 A Yes, sir.
23 o And in the five-year period that you've worked 23 O And you would stay until what time?
24 for Mr. Epstein, have you tried to go every day it you 24 A Sometimes 5:00, sometimes later. 5:30.
25 could? 25 o Would that depend on what needed to be done?
18 20
1 A Yes.
• 1
2
3
4
A No.
0 In a typical week would you normally go on
Sunday to mass?
A Yes, sir.
2
3
4
O How have you received your money. has it been
by Check, by cash, in terms of payment from Mr. Epstein?
A It's directly deposited to my bank
5 0 And how many days during the week will you 5 O Do you know who directly deposits your money?
6 also attend mass? 6 A MP?
7 A If the schedule permits, then Igo, but if 7 O Yeah. Mother Its Ghislaine Maxwell or a
not, then I don't go. 8 corporation or Jeffrey Epstein. do you knew who the
9 0 So is there a way that you could 9-IVO me an 9 direct depositor is of your check?
10 average of how many times a week that you go during the 10 MR. CRITTON: Form.
11 week to mass? 11 THE WITNESS: Mr. Epstein.
12 A This lime? 12 BY MR.-
13 0 Right. Yeah. I guess today, these days. 13 O Okay. Over the five years that you have been
14 A I attend Sunday masses only. 14 working at Mr. Epstein's house, how many conversations
15 0 And back in 2004, vmen you first started with 15 have you had directly with Mr. Epstein?
16 Mr. Epstein? 16 A What's this, what year?
17 A I filed to go it I have the time. sir. 17 O Wel. in the last five years, how many
18 O Was there ever a time that you went every day? 18 conversations have you had &cc* with Mr. Epstein?
19 A No. 19 MR. CRITTON: Form.
20 0 But your testimony is that if time permitted, 20 THE WITNESS: The past year it's just good
21 you tried to Go every day? 21 morning, how aro you. you're doing a good job.
22 A Yes. 22 BY MR. -
23 0 Is there a reason why now these days you only 23 O Okay. How was it prior to that, did you talk
24 attend on Sundays? 24 to him more?
25 A Because my time schedule has changed. 25 A This time more.
• 0
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 31410
www.esquiresolutions.com
CONFIDENTIAL 3501.172-001
Page 7 of 38
EFTA_00070813
EFTA01247536
- Volume I October 20, 2009
21 23
1
•
O Now you talk to him more? 1 A Yes.
2 A Because I serve him breakfast. so... 2 O When did you talk to Lyn Fontanilla about
3 O And is that an additional responsibility that 3
4 you didn't have before? 4 A It was just through the conversation.
A Yes. 5 O What would cause you to be in a conversation
6 O In the live-year penod that you've worked 6 with this person in New York?
7 there, can you name for me all of the other employees 7 MR. CRITTON: Form.
8 who have worked at the Jeffrey Epstein house? 8 THE WITNESS: She calls me, I call her.
9 A After Alfredo Rodriguez left, there was 9 BY MR.
10 Jerome. the gardener, and now it's Yanusz. 10 O You're friends?
11 O And those are the house managers'? 11 A Yes.
12 A Yes. 12 O Do you still talk to her today?
13 O And then you work there? 13 A Yes.
14 A Right. 14 O And does she work for Mr. Epstein as well, to
15 O Aside from yourself. Jerome. and Janusz. was 15 your knowledge?
16 there anybody else that you can remember working at the 16 A She does.
17 house in the past live years in any position? 17 O And does Jojo, her husband, also work for
18 A Yes. 18 Mr. Epstein as well?
19 O Who else? 19 A Yes, sir.
20 A 20 O Where do they work?
21 O That's 21 A In New York.
22 A Yes. 22 O At Mr. Epstein's house in New York?
23 O What does she do there? 23 A Yes, sir.
24 A She's the personal assistant. 24 O And have you talked with them about your
25 O Personal assistant to whom? 25 duties and has she talked to you about her duties?
22 24
•
1 A Mr. Epstein. 1 A YeSi sir.
2 O And as his personal assistant, what have you 2 O Arid your duties are similar to Lyn's duties in
3 observed her to do for him? 3 New York?
4 A Can you rephrase your question? 4 A No. Because that's a bigger house than...
5 O I can try. You sad that she's his personal 5 O Palm Beach?
6 assistant. What does that mean, what does she do? 6 A Yes, sir.
7 A Order things that I need. Ordi whats this. 7 O IS It your understanding that you know,
8 O So it's your testimony that has 8 we're going to gel into the past two years where
9 been. tor the past the years that you ve worked there. 9 Mr. Epstein has either been in jail or he's been on
10 has been somebody that you have observed to order things 10 house arrest in Palm Beach, so I'm going to ask you
11 that you reed? 11 first for the first three years that you worked there
12 A If I need something. than I go to ask 12 and Mr. Epstein was traveling, was Mr. Epstein spending
MI
13 O Oka . What other things have you seen 13 the majority of his time in Palm Beach or in New Yolk or
16 do for Mr. Epstein? 14 elsewhere. il you know?
15 A I have not, that's the any thing I know. 15 A He comes we don't know the schedule, we
16 O Who told you that is 16 receive a call, then we prepare, he's coming.
17 Mr. Epste,rts personal assistant? 17 O You say we receive a call. Who receives the
18 A Coworker. 18 calf?
19 O Who is that? 19 A Esther Alfredo or Janusz.
20 A In New York. 20 O Depending on who the house manager is at the
21 O What's that person's rerne? 21 time?
22 A Lyn. 22 A Yes.
23 O Lyn who? 23 O And the call comes from whom, from Dhislaine
24 A Fcetanala. 24 or from Jeffrey Epstein?
25 O Is that Jojo's wife? 25 A I don't know.
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE •••Insw•erGaloCeeptay
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
3501.172-001
CONFIDENTIAL Page 8 of 38
EFTA_00070814
EFTA01247537
- Volume I October 20, 200c;
25 27
1 O Okay. What's your understanding of Lyn's role 1 MR. CRITTON Form.
• 2
3
4
5
In Jeffrey Epstein's life up in New York?
A She's housekeeper, too.
O And your understanding of Jojo's role'
A A driver.
2
3
4
5
BY MR.
O
BY MR.-
Do you understand his question?
6 O Does he also serve as a house manager, similar 6 O Do you understand my question?
7 to the way Alfredo Rodriguez was in Palm Beach? 7 Do you know that is whim he's
A No. 8 asking you?
9 O Whon you say a driver, who does he drive. it 9 THE WITNESS: Yes.
10 you know? 10 I think the question was do you
11 A Mr. Epstein. 11 know whether or not Mr. Epstein pled guilty to
12 O All right. Mr. Epstein obviously hasn't been 12 comes.
13 in New York for quite some time: isn't that your 13 Was Mal the Ion?
14 understanding? 14 MR. Sure.
15 A Yes. 15 MR. CRITTON: That was not his question.
16 O So Jcicts still employed up In New York as a 16 BY MR. -
17 driver for Mr. Epstein, right? 17 O Okay. Well, do you realize that Mr. Epstein
18 A He also does housework, helps Lyn. 18 pled guilty to crimes?
19 O Have you discussed with Lyn whether or not 19 A Plead guilty? From the news.
20 young girls visit the house in New York? 20 O Okay. So when you say you saw the news, which
21 MR. CRITTON: Form. 21 is whore this portion or our discussion began, aro you
22 You can answer that. 22 referring to the news related to Mr. Epstein and the
23 BY MR. 23 charges, the criminal charges or criminal investigation
24 O He didn't lik
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.
I
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Donald Trump on, August 17, 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 _day of August, 2009 to all those on the
attached Service List.
EFTA00728377
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel:
Fax:
Email:
B
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reports
EFTA00728378
DataSet-10
Unknown
3 pages
JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JUDGE: CROW
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
AMENDED NOTICE OF TAKING DEPOSITION DUCES TECUM
(VIDEOTAPED)
PLEASE TAKE NOTICE that Pursuant to Rule 1.410 of the Florida Rules of Civil
Procedure, the undersigned attorney will take the deposition of Defendant/Counter-Plaintiff
Bradley J. Edwards on Wednesday, May 15, 2013 at 10:00AM at Empire Legal Support,
Inc., 401 East Las Olas Boulevard, Suite 1400, Fort Lauderdale, FL 33301, upon oral
examination before Empire Legal Support, Notaries Public, or any other notary public or officer
authorized by law to take depositions in the state of Florida. The oral examination will continue
all day and day to day thereafter until completed. 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 Court.
If you fail to appear, you may be in contempt of court. You are subpoenaed to appear by
EFTA00584744
the following attorney, and unless excused from this subpoena by this attorney or the court, you
shall respond to this subpoena as directed. This includes bringing with you the documents listed
in "Schedule A" attached hereto.
We hereby certify that this date was coordinated with opposing counsel, and that a true
and correct copy of this amended notice was served upon all parties listed in the service list
below, via Electronic Service, this April 22, 2013.
Tonja Haddad Coleman, Esq.
Fla. Bar No.: 0176737
LAW OFFICES OF TONIA HADDAD, PA
315 SE 7'h Street
Suite 301
Florida 33301
facsimile)
EFTA00584745
SCHEDULE A
(To Bring With You For Deposition)
1. Copies of income tax returns for the past five (5) calendar years of the
Defendant/Counter-Plaintiff Bradley J. Edwards (hereinafter "Edwards") (2007-2012).
2. Income tax records for the current tax year, and copies of any estimated income
tax returns filed for the current year for Edwards.
3. Copies of income tax returns for the past three (3) calendar years of Farmer, Jaffe,
Weissing, Edwards, Fistos & Lehrman, P.L.
4. Copies of all documentation related to all settlements, attorneys' fees awards, jury
verdict awards, and arbitration/mediation income received by Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L., and/or Bradley J. Edwards, PA.
5. Income tax records for the current tax year, and copies of any estimated income
tax returns filed for the current year for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,
P.L.
6. A copy of Edwards's (or Bradley J. Edwards, PA's) partnership agreement with
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
7. Copies of any and all documents, memoranda . . . upon which you rely in support
of your allegation of lost income/value of time diverted from your professional responsibilities as
alleged in your Counterclaim.
8. Copies of any and all documents, memoranda . . . upon which you rely in support
of your allegation of injury to your reputation as alleged in your Counterclaim.
9. Copies of any and all receipts, reports, or invoices evidencing treatment for your
mental anguish, embarrassment, and anxiety as alleged in your Counterclaim.
10. Copies of any and all receipts, reports, or invoices evidencing lost income
suffered as a result of your mental anguish, embarrassment, and anxiety as alleged in your
Counterclaim.
EFTA00584746
DataSet-10
Unknown
1 pages
From: "Lesley Groff" clIMIMa>
To: "Jeevacation"
Cc: ''': >, II=. 1 cas
Subject: Steve Osber
Date: Fri, 17 Dec 2010 20:48:18 +0000
Steve Osber had a quick break from his deposition in CA. He does not know when this will be over tonight so he cannot
give a time when he can call. I told him he can try the office line anytime he likes, someone should answer. He also gave
me his cell and said you may certainly try him as well. He will be back tomorrow evening. He said he works weekends
and it is fine to call him then also
Steve cell:
EFTA00648980
DataSet-10
Unknown
6 pages
i
IN THE CIRCUIT COURT OF THE le
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
BB, Case No: 502008CA 37319XXXX MB AB
Plaintiff,
Florida Bar No: 089737
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
DATE AND TIME: LOCATION:
August 14, 2009 Burman Critton et al
10:00 AM
fl
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 under the Rules of the Court.
WE HEREBY CERTIFY that a true and maile• thi
to Jack A. Goldberger,
1111L • Bruce E. Reinhart, Esq.,
• Robert D. Critton, Jr., Michael J. Pike
LEOPOLD-KUVIN. P.A.
Spencer T. ICuvin,
Fl. Bar No.: 089737
EFTA00722974
IN THE CIRCUIT COURT OF THE 15Th
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
BB, Case No: 502008CA 37319XXXX MB AB
Plaintiff,
Florida Bar No: 089737
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
Ghislane Noelle Maxwell August 17, 2009 Esquire Court Reporters
11:00 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 under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct co of this Notice was mailed this
da y of Au st, 2009 to Jack A. Goldberger, Es
Bruce E. Reinhart, Esq.,
Robert D. Critton, Jr., Mic
LEOPOLD--KUVIN, P.A.
t.
Fl. Bar No.: 089737
EFTA00722975
IN THE CIRCUIT COURT OF TIM 15Th
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY
B.B. Case No: 502008 CA 37319XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: PATE AND TIME: LOCATION:
Glenn Russell Dubin August 18, 2009 Esquire Court Reporters
11:00 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 under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy f his Notice was faxed and mailed
to: Jack A. Goldberger, .
Bruce E. Reinhart, Esq.,
D. Critton, Jr., • c,
LEOPOLD-ICUV1N P.A.
B
Spencer . Kuvm, Esq.
Florida Bar No: 089737
EFTA00722976
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
B.B Case No: 502008CA037319XXXXMB AB
Plaintiff,
VS.
JEFFREY EPSTEIN and
Defendant.
PLAINTIFF'S 7th RE-NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: • DATE AND TIME: LOCATION:
Jeffrey Epstein September 2, 2009 Atterbur Goldber er Weiss
do Burman, Critton, Luther, 10:00 AM
& Coleman LLP
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 under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was faxed and mailed
this A day of August, 2009, to: Jack A. Goldberger, Esq/Bruce E. Reinhart, Esq., Atterbury
Goldberger & Weiss, P.A., ; Robert
Critton. Esq., Burman, Critton, Luttier & Coleman, LLP,
LEOPOLD-KUVIN PA.
r
By:
Cc: Pleasanton Greenhill Florida Bar No: 089737
Visual Evidence
EFTA00722977
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
B.B Case No: 502008CA037319)OCXXMB AB
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S RE-NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
September 21, 2009 McIntosh Sawran Peltz &
1:00 PM
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 under the Rules of the Court.
I HEREBY CERTIFY that a true and correct co of this Notice was mailed this
o: Jack A. Goldberger,
Bruce E. Reinhart, Esq.,
R -rt D. Critton, Jr., Michael J. Pike,
Dou las McIntosh, Esq./Camille Blanton, Esq.,
LEOPOLD-KUVIN P.A.
By:
Spend T.
Florida Bar No: 089737
Cc: Pleasanton Greenhill
Visual Evidence
EFTA00722978
Epstein Matter
Depositions Currently Scheduled
as of August 10, 2009
T;blatri
Doe and Leslie Wexler 8/14/09,11:00a.m McGinnis & Assoc. Noticed by
Doe 101, By video .Cancelled but Edwards, cross
102 no notice yet notice by
Josefsberg,
U.S.Legal
B.B. 8/14/09,10:00a.m Burman,Critton Noticed by Kuvin
By Video
Doe, Ghislane Noelle 8/17/09,11:00a.m Esquire Court Rep Noticed by
Doe 101 Maxwell Edwards, cross
Doe 102 By video notice by
B.B. Josefsberg, by BB
U.S.Legal
- same - Glenn Russell 8/18/09 11:00a.m - same - - same -
Dubin
By video
B.B. Donald Trump 8/18/09,11:00a.m - same - Noticed by Kuvin
B.B. 9/01/09,11:00a.m Esquire Court Rep - same -
By video
B.B. Jeffrey Epstein 9/02/09,10:00a.m Atterburv.Goldbe er - same -
By video
B.B. 9/21/09,1:00 p.m McIntosh Sawran - same -
By video
EFTA00722979
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
Jean Luc Bruhel on Tuesday, September 22, 2009, at 10:00 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 // day of August, 2009 to all those on the
attached Service List.
1
EFTA00725580
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel:
Fax:
Em
B
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reporters
EFTA00725581
DataSet-10
Unknown
1 pages
From: "-(USANYS)" cMIMIMIN>
To: ' (USANYS)"
Cc: (USANYS)"
Subject: Re: Epstein
Date: Fri, 30 Nov 2018 12:31:22 +0000
Importance: Normal
I think a way of firmly and likely publicly staking claim (which is probably the way to go here) is to subpoena
the civil lawyer in case v Epstein for deposition transcripts and other materials.
Sent from my iPhone
> On Nov 30, 2018, at 7:04 AM, (USANYS) alMIE> wrote:
> Mad asked for a memo, which we've ha' draft. We'll review this morning and circulate. As
discussed, we're also in touch with FBI - they are in the process of pulling/reviewing the old case file. Can we
plan to touch base on this and a few other outstanding issues this morning?
> Sent from my iPhone
>> On Nov 30, 2018, at 6:58 AM, (USANYS) allIMIN> wrote:
>> Another article in the NYT today. How are we putting down our marker?
>> Sent from my iPhone
EFTA00089844
DataSet-10
Unknown
3 pages
From: G Maxwell
To: Jeffrey Epstein
Subject: Re: Daily Mail story
Date: Fri, 04 Apr 2014 02:44:07 +0000
That mentions me right in detail? What more can they say? This is dredging up all the lies in her deposition in
more detail like it's new..god I hate them - WTF..so many more important things to talk about and stories that
are real not made for money or fame..
Ok
Keep me posted
FACEBOOK - TWITTER -
G+ - PINTEREST
- INSTAGRAM - PLEDGE
- THE DAILY CATCH
wrote:
Hi there - what is this referencing
Gx
FACEBOOK
TWITTER
G+
PINTEREST
PLEDGE
THE DAILY CATCH
Date: Thursday, April 3, 2014 21:31PM
To: J Jep
Subject: Fw: Daily Mail story
FACEBOOK - TWITTER chttp://twitter.com/terramarproject>
- G+ - PINTEREST
- INSTAGRAM PLEDGE
EFTA00987389
- THE DAILY CATCH
.
M collea ue Gu is reached thou h the office switchboard in the UK which is + •
> or
Thanks
Daniel[https://mail.google.com/maillu/Olimages/cleardot.gif]
***********************************************************
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
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
EFTA00987390
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
EFTA00987391
DataSet-10
Unknown
1 pages
a 0
IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs. NOTICE OF DEPOSITION
JEFFREY EPSTEIN,
Defendant. STATE OF FICFIIDA • PALM BEACH EVA., (
I hereby certify that the
foregoing is a true copy
of the record In qy office
TO: Lamm Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
West Palm Beach, Florida 33401 ST 0CO
PLEASE TAKE NOTICE that pursuant to the Florida les of du% that oht
March 24. 2008 beginning at the hour of 1:30 P.M. at the Palm Beach CounW rifirtkouse.X
C-12 C7
Floor, 205 North Dixie Highway, West Palm Beach, Florida 33401:
Eng -0 M
before Consor & Associates who is authorized by law to take depositions in the STA%Fligida, the
ea
Plaintiffs will, upon oral examination, take the deposition of the following nam 949elephone, to
wit:
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 17th day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
Wes Palm B ch, Florida 33401
A A. GOLDBERGER, ESQUIRE
Fl ida Bar No. 262013
MM15-STATE CASE-000187
3501.014-037
Page I of I
CONFIDENTIAL
EFTA_00056459
EFTA01245409
DataSet-10
Unknown
5 pages
LEOPOLD-KUVINL,
CONSUMER JUSTICE ATTORNEYS
May 6, 2010
CERTIFIED MAIL RETURN
RECEIPT REQUESTED
Re: Jeffrey Epstein
Dear .=
Enclosed please find a copy of Re-notice of Taking your Deposition which is now scheduled for
Tuesday, June 15, 2010 beginning at 10:00 a.m.
Please be advised that you are still under subpoena and your appearance at this deposition
is mandatory.
Should you have any questions, please don't hesitate to contact me at your convenience.
fl
CRASHWORTHINESS • MANAGED CARE ABUSE
3 fax
CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
EFTA00724180
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
C. L. Case No: 10-80447-cv-Marra/Johnson
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S RE-NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
• DATE AND TIME: LOCATION:
June 15, 2010
10:00 AM
upon an oral examination before Vidcographer 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.
i.
WE HEREBY CERTIFY that a true and correct co
to Jack A. Goldberger,
; Bruce E. Reinhart, Esq.,
• Robert D. Critton, Jr., Michael J. Pike,
of this Notice was mailed this 7
LEOPOLD-KUVIN, P.A.
By:
ce s. yin, Esq.
Cc: Prose Court Reporting Florida Bar No: 089737
Visual Evidence
EFTA00724181
Farmer, Jaffe, Weissing,
Ian Action
Edwards, Fistos Et Lehrman, P.L.
Pe rsor.a: Injury
Wrotig10 Death
Commercial Litiganon
OJUSTICE.00M
May 7, 2010
Honorable Donald W. Hafele
Main Judicial Complex
Palm Beach County Courthouse
205 North Dixie Highway, Room 11.1204
West Palm Beach, Florida 33401
Re: LM. v. Jeffrey Epstein /Case No. 502008CA02t3051)OO(MB AB -and-
E.W. v. Jeffrey Epstein / Case No. 50200SCP003626XXXXMB
Dear Judge Hafele:
Enclosed please find copies of Plaintiffs' proposed Agreed Orders concerning the hearing
on Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiff's
Second Amended Complaint that took place on April 9, 2010, in the above-captioned matters.
Should both of these Agreed Orders meet with Your Honor's approval, please execute
same in both matters and provide conformed copies to all counsel in the enclosed prepaid self-
addressed envelopes provided.
If you have any questions, please feel free to call.
hank you for your time and attention to this matter.
armer, J
End es as stated
GMF/nas
cc: Robert D. Critton, Esq. ✓
Jay Howell, Esq.
Jack Goldberger, Esq.
EFTA00724182
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.
AGREED ORDER ON DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PARTIAL
SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT
THIS CAUSE came on to be heard on April 9, 2010 upon Defendant, Jeffrey Epstein's
Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint; the
Court having reviewed and considered the motion and the record and otherwise being fully
advised in the premises, it is hereby
ORDERED AND ADJUDGED that:
During the hearing, Plaintiffs counsel indicated a desire to amend the Complaint. As
such, the Court will deny as moot Defendant, Jeffrey Epstein's Motion for Partial Summary
Judgment on Count I of Plaintiffs Second Amended Complaint at this time so as to allow the
Plaintiff, L.M. to file an Amended Complaint within twenty (20) days of the date of this Order.
Thereafter, Defendant. Jeffrey Epstein shall have twenty (20) days to file a responsive pleading.
DONE AND ORDERED at Palm Beach County Courthouse, Palm Beach County, Florida,
this day of 2010.
HONORABLE DONALD W. HAFELE
Circuit Court Judge
COoleS furnished to•
Gary M. Farmer, Jr., Esq.
Bradley J. Edwards. Esq.
Robert D. Critton, Jr., Esq.
Jay Howell, Esq.
Jack Alan Goldberger, Esq.
EFTA00724183
IN THE CIRCUIT COURT FOR THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM BEACH
COUNTY. FLORIDA
CASE NO. 502008CP003626XXXXMB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
AGREED ORDER ON DEFENDANT. JEFFREY EPSTEIN'S MOTION FOR PARTIAL
SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT
THIS CAUSE came on to be heard on April 9, 2010 upon Defendant, Jeffrey Epstein's
Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint; the
Court having reviewed and considered the motion and the record and otherwise being fully
advised in the premises, it is hereby
ORDERED AND ADJUDGED that:
During the hearing, Plaintiffs counsel indicated a desire to amend the Complaint. As
such, the Court will deny as moot Defendant, Jeffrey Epstein's Motion for Partial Summary
Judgment on Count I of Plaintiff's Second Amended Complaint at this time so as to allow the
Plaintiff, E.W. to file an Amended Complaint within twenty (20) days of the date of this Order.
Thereafter, Defendant, Jeffrey Epstein shall have twenty (20) days to file a responsive pleading.
DONE AND ORDERED at Palm Beach County Courthouse, Palm Beach County, Florida,
this day of , 2010.
Copies furnished to: HONORABLE DONALD W. HAFELE
Gary M. Farmer, Jr., Esq. Circuit Court Judge
Bradley J. Edwards. Esq.
Robert D. Craton, Jr., Esq.
Jay Howell, Esq.
Jack Man Goldberger, Esq.
EFTA00724184
DataSet-10
Unknown
3 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
v. No. 17 Civ. 00616 (JGK)
pi...LESLEY
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
SHEV,
GROFF and
Defendants.
PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION
OF GHISLAINE MAXWELL
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: Ghislaine Maxwell
DATE AND TIME: October 15, 2018 at 10:00 a.m.
LOCATION: Boies Schiller Flexner LLP
575 Lexington Avenue, 7th Floor
New York, NY 10022
The videotaped deposition will be taken upon oral examination before Magna Legal
Service, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
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.
I
EFTA00808200
Dated: September 26, 2018.
BOLES SCHILLER FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boles Schiller Flexner LLP
Bradley J. Edwards, Esq. (Admitted Pro Hac Vice)
Stanley Pottinger, Esq.
Paul G. Cassell (Admitted Pro Hac Vice)
S.J. Quinney College of Law
nivetsity of
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
EFTA00808201
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of September, 2018, I served the attached
PLAINTIFFS RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE
MAXWELL via Email to the following counsel of record.
Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
Scott J. Link
Counselfor Jeffrey Epstein, and Lesley Groff
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON. R AN & FOREMAN. P.C.
Counselfor Ghislaine Maxwell
By: /s/ SigridMcCawley
Sigrid McCawley
3
EFTA00808202
DataSet-10
Unknown
17 pages
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA028058XXXXMB AB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
AND FOR SANCTIONS
EPSTEIN'S MOTION TO COMPEL DEPOSITION OF EW
an order compelling
Defendant, JEFFREY EPSTEIN ("Epstein"), moves for
s for sanctions, and states:
Plaintiff, E.W. ("EW"), to appear for deposition, move
mber 11, 2009
1. EW's deposition was originally set for deposition on Septe
t her deposition to November 5
(Notice attached as Exhibit A). Epstein agreed to re-se
counsel, Brad Edwards, was
and 6, 2010 (Notice attached as Exhibit B) since her
.
scheduled for surgery on or around September 11, 2009
y cancelled by
2. The November 5 and 6, 2010 depositions were unilaterall
, Rosenfeldt & Adler firm. See
EW's counsel because of the implosion of the Rothstein
Exhibit C.
November 2, 2009 e-mail from Jacquie Johnson attached as
of Taking Video
3. On March 9, 2010, Epstein again served a Notice
hed as Exhibit D). On all
Deposition of EW to occur on April 2, 2010 (Notice attac
rmed with opposing counsel.
occasions, the deposition dates were coordinated and confi
would be
4. Despite assurances from her counsel on April 1, 2010 that she
2010 (Certificate of Non-
attending, EW failed to appear for her deposition on April 2,
Appearance attached as Exhibit E).
EFTA01103285
5. Brad Edwards, counsel for EW, explained on the record that he arranged
to pick EW up for her deposition at a pre-arranged location the morning of April 2, 2010.
See Exhibit D at 3-4. However, when Mr. Edwards arrived at said location EW was not
there. Id.
6. Mr. Edwards attempted to contact EW "on many occasions this morning
by way of cellphone, and there is no, there has been no answer on the cellphone." Id.
at 4. Mr. Edwards also called a home phone number to no avail. Id.
7. Mr. Edwards apparently learned, through an unidentified "friend" of EW,
that she had to attend to a health issue related to her mother. Id. at 4-5. Yet EW made
no attempt to contact Mr. Edwards and advise of any health issue; instead she again
ignored her deposition notice and failed to appear.
8. In addition to being a plaintiff in the instant case, EW is also an important
witness in related federal companion cases, which are subject to fast approaching
discovery deadlines. Specifically, the discovery cutoff in Jane Doe v. Epstein, Case No.
08-80893-CV-MARRA/JOHNSON was recently extended to April 16, 2010. See DE
#473. EW is an important witness in the foregoing case as she was a close friend of
Jane Doe and possesses relevant information necessary for Epstein to defend the case.
The Court should therefore compel her attendance at deposition on or before April 16,
2010 (although Mr. Edwards has agreed to extend the discovery deadline and provide
another date when EW "may" actually appear).
9. Because of the importance of obtaining EW's testimony in the related
federal matters, Epstein also requests the Court order that if EW fails to appear for
deposition on or before April 16, 2010 (or an agreed date with her attorney who is also
2
EFTA01103286
n) that an order to show cause be
the attorney in the Jane Doe case referenced herei
is attached as Exhibit F.
issued and a show cause hearing set. A proposed order
of Civil Procedure
10. Moreover, EW's callous disregard for the Florida Rules
fees by virtue of the undersigned
has caused Epstein to incur unnecessary attorney's
in has also incurred unnecessary
preparing for and attending the deposition. Epste
.00 (invoices attached as composite
court reporter and videographer costs, totaling $710
Exhibit 6).
des in pertinent part:
11. Rule 1.380(d), Florida Rules of Civil Procedure, provi
to
If a party ... fails (1) to appear before the officer who is
r notic e,
take the deposition after being served with a prope
any
... the court in which the action is pending may take
and (C) of
action authorized under paragraphs (A), (B),
in
subdivision (b)(2) of this rule. ... Instead of any order or
party failin g to
addition to it the court shall require the
by the
act to pay the reasonable expenses caused
failure, which may include attorneys ' fees. ...
(Emphasis added).
in's counsel's
12. Epstein requests the Court require EW to pay Epste
, for preparing the instant
attorney's fees for attending her deposition on April 2, 2010
incurred due to her failure to
motion and attending hearing on same, and for the costs
an award of attorney's fees
attend the April 2, 2010 deposition.' Epstein also requests
, which will include the
for the time it will take to again prepare for EW's deposition
s.
review of hundreds, if not thousands, of pages of document
sts the Court compel
WHEREFORE, Defendant, JEFFREY EPSTEIN, reque
16, 2010 (or date agreed to by
Plaintiff, E.W., to attend her deposition on or before April
Epstein will supply the Court with an affidavit
If the Court grants Epstein's entitlement to attorney's fees,
attesting to the fees incurred and which Epstein is claiming.
3
EFTA01103287
of an ord er to show cause in the event E.W. fails
her counsel), provide for the issuance
tein
0 (or the agreed upon date), award Eps
to appear on or before April 16, 201
and grant
EW 's failure to appear on April 2, 2010
attorney's fees and costs based on
just and proper.
any additional relief the Court deems
CERTIFICATE OF SERVICE
the foregoing was sent by fax and U.S.
I HEREBY CERTIFY that a true copy of
this 8th day of April, 2010:
Mail to the following addressees on
Jack Alan Goldberger, Esq.
Brad Edwards, Esq.
Atterbury Goldberger & Weiss, P.A.
Farmer, Jaffe, Weissing, Edwards, Fistos
250 Australian Avenue South
& Lehrman, PL
Suite 1400
424 N. Andrews Avenue, Suite 2
der dale , FL 333 01 West Palm Beach, FL 33401-5012
For t Lau
Fax:
- fax Co-Counsel for Defendant Jeffrey Epstein
Counse or am
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
Fax
Co-counsel or Plaintiff
LLP
BURMAN CRITTON LUTTIER & COLEMAN,
303 Banyan Boulev Suite 400
st Palm Bea 3401
By:
Robert D. C
Florida Ba #224162
Michael J. Pike
Florida Bar #617296
David A. Yarema
Florida Bar #12492
4
EFTA01103288
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY. FLORIDA
L.M.,
CASE NO. 502008CA028051/OOO{MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
y will take the deposition via video of:
PLEASE TAKE NOTICE that the undersigned attorne
PATE & TIME LOCATION OF DEPOSITION
DEPONENT
Friday Burman Critton Luther & Coleman,
EW
September 11, 2009 LLC
do Brad Edwards, Esq.
303 Banyan Boulevard
Rothstein Rosenfeldt Adler 10:00 a.m.
Suite 400
401 East Las Olas Boulevard West Palm Beach, FL 33401
Suite 1650
Fort Lauderdale, FL 33301
y. Inc., a Notary Public, or any other officer
upon oral examination, before Prose Court Reporting Agenc
The oral examination is being taken for the
authorized by law to take depositions in the State of Florida.
es as are permitted under the applicable
purpose of discovery, for use at trial, or for such other purpos
Statutes of Rules of Court.
has been furnished by electronic mail
I HEREBY CERTIFY that a true copy of the foregoing
Service List this 91 th day of August, 2009.
(e-mail) and U.S. Mail to the addresses listed on the below
BURMAN, CRITTON, LUTHER & COLEMAN
303 Banyan Blvd., Suite 400
West Palm Beach, FL 3340
5611842-2820
BY:
ROBER . CRITTON, JR., ESQ.
Florida ar No. 224162
MICHAEL J. PIKE, ESQ.
Florida Bar. No. 617296
(Counselfor Defendant Jeffrey Epstein)
Courtesy copy: Prose Court Reporting Agency, Inc.
EXHIBIT k
EFTA01103289
L.M. v. Epstein
Page 2
L.M. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Rothstein Rosenfeldt Adler Atterbury Goldberger & Weiss, P.A.
401 East Las Olas Boulevard 250 Australian Avenue South
Suite 1650 Suite 1400
Fort Lauderdale FL 33301 West Palm Beach, FL 33401-5012
Phone: Fax:
Fax: Co• ounse orDefendant Jeffrey Epstein
Counse
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
Fax
Co-counsel for Plaintiff
EFTA01103290
1+O
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.W.,
CASE NO. 5020013CA028058,OOO(MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition via video of:
DEPONENT DATE & TIME LOCATION OF DEPOSITION
E.W. Thursday, Prose Court Reporting
do Brad Edwards, Esq. November 5, 2009 250 Australian Avenue S., Suite #1500
Rothstein Roseofeldt Adler and Friday, West Palm Beach, FL 33401
401 East Las Olas Boulevard November 6, 2009
Suite 1650 beginning at
Fort Lauderdale, FL 33301 10:00 a.m.
upon oral examination, before Prose Court Reporting Agency, 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
of Rules of Court.
I HEREBY CERTIFY that a true copy of the foregoing was sent by electronic mail (e-mail) and by
US Mail to the addresses listed on the below Service List on this 20th day of October 2009.
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West Palm Beac FL 33401
By:
obert D. Critton, Jr.
Florida Bar #224162
Michael J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EXHIBIT B
EFTA01103291
E.W. v. Epstein
Page 2
g.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Brad F,dwards and Associates, LLC Atterbury Goldberger & Weiss, P.A.
2028 Harrison Street 250 Australian Avenue South
Suite 202 Suite 1400
Holl d FL 33020 West Palm Beach. FL 33401-5012
hone Faxes
ax Co-Cotmselfor Defendant Jeffrey Epstein
Counselfor Plaintiff
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesay Boulevard
Suite 250
Jacksonville, FL 32211
hone
Fax
Co-counselfor Plaintiff
EFTA01103292
Page 1 of 1
Jessica Cadwell
From: Jacquie Johnso
Sent: Monday, November 02, 2009 12:14 PM
To: Jessica Cadwell; Connie Zaguirre
Subject: Deposition of EW
Due to certain circumstances at
RRA — we have no choic
But to cancel the deposition
of EW this week.
Jacquie Johnson
Legal Assistant to
Brad Edwards, Esq.
Partner
Rothstein Rosenfeldt Adler
401 East Las Olas Blvd.
Suite 1650
Fort Lauderdale FL 33301
Tele hone
Fa
EXHIBIT C
4/8/2010
EFTA01103293
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.W.,
CASE NO. 502008CA028058XXVIMB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
the deposition via video of:
PLEASE TAKE NOTICE that the undersigned attorney will take
DATE & TIME LOCATION OF DEPOSITION
DEPONENT
April 2, 2010 at Prose Court Reporting
E.W.
do Brad Edwards, Esq. 9:00 a.m. 250 Australian Avenue S.
Suite #1500
Fanner, Jaffe, Weissing, Edwards,
West Palm Beach,FL 33401
Fistos & Lehrman, P.L.
425 N. Andrews Avenue
Suite #2
Fort Lauderdale,FL 33301
y, Inc., a Notary Public, or any other officer
upon oral examination, before Prose Court Reporting Agenc The oral examination is being taken for the
authorized by law to take depositions in the State of Florida.
as are permitted under the applicable Statutes
purpose of discovery, for use at trial, or for such other purposes
ofRules of Court.
by electronic mail (e-mail) and by
I HEREBY CERTIFY that a true copy of the foregoing was sent . 2010.
9ib day of March
US Mail to the addresses listed on the below Service List on this
BURMAN, CRTITON, urrnER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
West P , FL 3 01
11111Fax
By:
RobedD ritton, Jr.
Florida #224162
Mic J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EXHIBIfp
EFTA01103294
E.W. v. Epstein
Page 2
E.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Fanner, Jaffe, Weissing, Edwards, Flstos & Atterbury Goldberger & Weiss, P.A.
Lehrman, P.L. 250 Australian Avenue South
425 N. Andrews Avenue Suite 1400
Suite 2 West Palm Beach, FL 33401-5012
Ft. Lauderdale, FL Fax:
Phone Co-Counselfor Defendant Jeffrey Epstein
Fax
Counse or aitufff
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
hone
ax
Co-counse
Wor Plaintiff
EFTA01103295
Page 3
Page 1
IT 1 PROCEEDINGS
IN THE CIRCUIT COURT OF THE 15M JUDICIAL CIRCU
IN AND FOR PALM BEACH COUNTY, FLORIDA 2
CASE NO. 502008CA028058200CXMII AD 3 MR. CRITTON: All right. We're here for
E.W., 4 the deposition of E.W. which was duly noticed
5 today for 9:O0. We continued with Mr. Edward's
Plaintiff, 6 office yesterday that the deposition was on.
7 He =Daunted they would be here at 9:00 for
8 the deposition.
JEFFREY EPSTEIN, 9 He sent me some -- we had made a request
Decadent. 10 for his Answers to Interrogatories which were
11 due yesterday. They provided me their answers
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OF 12 and objections to I think it was the fourth set
E.W. 13 of interrogatories. And I have been preparing
14 for nine years -- no, certainly for a couple of
Friday, April 2, 2010
9:20 • 9:22 a.m. 15 days, but Mr. Edwards has just advised me she
16 probably, Ms. E.W. will probably not be here
250 Australia Avenue South 17 today, but I will let him speak for himself.
Suite 1500
West Palm Beach, Florida 33401 18 MR. EDWARDS: Sure. Just so the record is
19 clear, I have had frequent and constant
Reported By:
20 communication with E.W. over the last month.
Cynthia Hopkins, RPR, FM 21 As recently as Wednesday she was in my office
Notary Public, State of Florida 22 for the pre-deposition conference, met for
Prose Court Reporting several hours, was certainly intending on being
JobNo. 1612 23
24 here, communications with E.W. as late as 8:00
25 last night where we made arrangements for her
Page 4
Page 2
1 APPEARANCES: 1 to be at this deposition which included me
2 On behalf of the Plaintiffs, LM., E.W. and 2 picking her up this morning.
Jane Doe: 3 I showed up to the location and she was
3
BRADLEY J. EDWARDS, ESQUIRE 4 not, she was not there. The information that
4 FARMER, JAFFE, WEISSING, EDWARDS 5 has been relayed to me in the last hour is that
FISTOS & LEHRMAN, P.L. 6 there was a health issue related to her mother
5 425 North Andrews Avenue
Suite 2 7 last night that she had to attend to.
6 Fort Lauderdale, Florida 33301 8 I have attempted to contact E.W. on many
Phone: 954,524.2820 9 occasions this morning by way of cellphone, and
7
8 10 there is no, there has been no answer on the
9 On behalf of the Defendant, Jeffrey Epstein: 11 cellphone. And I have also made attempts to
10 ROBERT D. CRITTON, JR., ESQUIRE 12 contact at another home phone where she has
BURMAN, CIUTTON, LUTTEER & COLEMAN, LLP
11 303 Banyan Boulevard 13 stayed recently, and there was no answer at
Suite 400 14 that phone as well.
12 West Palm Beach, Florida 33401 15 So, at this point in time all indications
Phone: 561.842.2820
16 are that she will not be here for her
13
14 ALSO PRESENT 17 deposition today.
15 Sascha Quiinby, Videographa 18 MR. CRITTON: Just for clarification,
16
17 19 Brad, did you actually speak with someone? I
18 20 mean, I know you spoke with E.W. last night
19 21 She was going to come. And then have you, I
20 22 thought you said you spoke with someone to try
21
22 23 to locate her.
23 24 Do you want to disclose who that person
24 is?
25
25
1 (Pages 1 to 4)
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
bfd075ea-b36a-4201-a365-853c87821878
Electronically signed by cynthia hooking
EFTA01103296
Page 7
Page 5
1 CERTIFICATE
MR. EDWARDS: Not at this time I don't.
2
2 If the court wants me to disclose, I will, but
3 STATE OF FLORIDA
3 it is a friend of E.W.'s who spoke with her
4 COUNTY OF PALM BEACH
4 later last night than the time when I spoke to
5
5 her.
6
6 MR. CRITTON: Okay. Did you get any 7 I, Cynthia Hopkins, Registered Professional
7 inclination at that time that there was any Reporter and Florida Professional Reporter, State of
8 problem with family or friends? 9 Florida at large, certify that I was authorized to
9 MR. EDWARDS: At the time that I spoke 10 and did stenographically report the foregoing
10 with E.W.? 11 proceedings and that the transcript is a true and
11 MR. CRITTON: No, with the other person. 12 complete record of my stenographic notes.
12 MR. EDWARDS: That conversation happened 13 Dated this 2nd day of April, 2010.
13 within the last hour this morning. 14
14 MR. CRITTON: Okay. All right. We'll 15
15 take a C.N.A., and I actually have been 16
16 preparing for this for a couple of days.
17 E.W. has a lot of information on her. She 17
18 is obviou sly a key witness. She is an 18 Job #1612
19 important witness in a number of cases 19
20 including the Jane Doe case which discovery 20
21 ends on the 16th and Mr. Edwards and I have 21
22 worked out some extensions on that. We may 22
23 have to work out some others to our mutual 23
24 benefit so we can complete the deposition or 24
attempt to take Ms. E.W.'s deposition. 25
25
Page 6
1 So, we'll take a C.N.A. and I will do what
2 I need to do in court. Thank you.
3 MR. EDWARDS: Agreed_
4 (The deposition was concluded.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
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21
22
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2 (Pages 5 to 7)
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
bfd0Th ea-b36a -4201-a368853087821878
Electronically signed by synth's hopidnit t
EFTA01103297
Page 1
IN THE CIRCUIT COURT OP THE 15TH JUDICIAL CIRCLET
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. S0200SCA02005820000.03 AD
Plaintiff.
JEFFREY EPSTEIN,
Defendant.
/
CERTIFICATE OF NON-APPEARANCE
I, Cynthia Hopkins, Registered Professional
Reporter and Notary Public, State of Florida at
Large, was duly designated to lake the deposition of
the witness:
E.W.
I hereby certify that aforesaid witness did
not appear beton me between 900 a.m. and 9:30 a.m.
on the 2nd day of April, 2010. Present was
Robed D. Critton, Jr., Esquire, and Bradley J.
Edwards, Esquire.
Dated this 2nd day ofMail, 2010.
ttal Hopkins,
".: AS
Prose Court Reporting Agency. Inc,
West Palm Beach, Florida
1. (Page 1)
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
24032db3-ead8-484calfdcf14eb399692
Electronically signed by cynthia hopkins
EFTA01103298
THE FIFTEENTH
IN THE COURT OF
AND FOR PALM
JUDICIAL CIRCUIT, IN
BEACH COUNTY, FLORIDA
XXXXMB AB
E.W., CASE NO. 502008CA028058
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
TION TO COMPEL
ORDER ON EPSTEIN'S MO
R SANCTIONS
DEPOSITION OF EW AND FO
Compel
bef ore the Co urt on De fendant Epstein's Motion to
THIS CAUSE came
ent of counsel and being
an d for Sa nct ion s, and the Court having heard argum
Deposition of EW
es, it is hereby
fully advised in these premis
ANTED.
DE RE D an d AD JU DG ED that Defendant's Motion is GR
OR
on or before
(1) EW shall appear for deposition
she is
EW fail s to app ear for deposition on or before
(2) If
2010 at a.m.lp.m to
bef ore the und ers ign ed on
commanded to appear
tion.
be he ld in con tem pt of cou rt for failing to appear for deposi
no t
show cause why she should
her failure to appear
in is en title d to rec ove r fro m EW $710.00 in costs for
(3) Epste
sition on April 2, 2010.
at her properly noticed depo
r attorney's fees from EW due to her failure to attend
(4) Epstein is entitled to recove
ure hearing).
on April 2, 2010 (am ount to be determined at a fut
her properly noticed deposition
Florida,
lm Beach County Co urthouse, West Palm Beach,
DONE AND ORDERED at Pa
day of 2010.
this
Donald Hafele
Circuit Court Judge
01,
400, West Palm Beach, FL 334
Copies furnished:
., and MIC HAE L J. PIK E, ESQ ., 303 Banyan Boulevard, Suite And rew s Ave nue , Suit e 2, Fort
N.
ROBERT D. CRITTON, JR.. ESQ mer, Jaffe. Weissing, Edwards, Fistos & Lehrman, PL. 425 rd, Suite 250. Jacksonville, FL
., Far tes. PA, 644 Cesery Bouleva
BRADLEY J. EDWARDS, ESQ
ELL. ESQ., Jay Howell & Associa Weiss, PA, 250 Australian Avenue South, Suite 1400 West
Lauderdale, FL 33301, JAY HOW Gold berg er &
ER. ESQ.. Atterbury
32211, and JACK A. GOLDBERG
Palm Bea ch, FL 334 01-5 012 .
EXH{BIT F
EFTA01103299
INVOICE
Invoice No. Invoice Date Job No.
E I
I PR OS 5599 4/3/2010 1612
coin Job Date Case No.
UPORTING AGENCY, Bit 412/2010 902008CA028038)00C04BAF
Case Name
E.W. v Epstein
Robert Critton, ESquire Payment Terms
Burman, OBTOR Lutber & Colman, LIP
303 Banyan Boulevard, Suite 400 Due upon receipt
West Pam Beach, FL 33401
Scheduled Deposition of EW. 110.00
110.00
Certification of Non-Appearance 75.00
75.00
Large Conference Room - 1Hour
TOTAL DUE .> > $185.00
We appreciate your business! Payment Is due upon receipt
customersrnke@prosaaa.com
Please contact us with any cares:ions: (561)832-75001
Tax ID: 26-3892897
Please *tack bottom pothon andreturn withpayment.
Job No. : 1612 BD ID : 1-MAIN
Case No. : 502008CA0280S8XXXAMB AF
Robert °Won, Esquire
Borman, Cntton, Luther & Coleman, LLP Case Name : E.W. v Epstein
303 Barryan BoulearO, Suite 400
West Palm Beath, Ft. 33401 5549 Invoice Date :4/3/2010
Invoke NO.
Total Due : $185.00
PAYMENT WITH CREDIT CARD
carcutdersName: EXH!BIT
Card Number:
Remit To: Prose Court Reporting Agency, Inc. lryn oAM Phone*:
One aearlake Centre
250 S. Australian Ave., Suite 1500
West Palm Beach, FL 33401 Card Security Code:
Amount to Charge:
Certriolder's Signature.
EFTA01103300
Invoice
VISUAL
Date Number
EVIDENCE Went Pain'. Fi 3Ws 4/2/2010 29683
Box 6967
Terms
Due on receipt
BURMAN, CRITTON & LUTHER
ROBERT CRITTON
303 BANYAN BLVD
SUITE 400
WEST PALM BEACH, FL 33401
Case / Reference; 7 E.W. vs EPSTEIN
(NY Amount
Services Rendered
Date
4/2/2010 VIDEOTAPED DEPOSITION OF: E.W.
DEPONENT
DEPO CANCELLED DUE TO NO-SHOW BY 1 275.00
Tech Time - 1ST 2 Hours 1 500.00
Portable VideOwnlerencing System - 1/2 day -250.00
Discount PER M.D.
TOTAL: $525.00
r your presentation needs. Remit to:
Adapting our services to meet
Visit: www. visua /evidence. corn P.O. Box 6967
West Palm Beach FL 33405
d Tax ID #
Fax: (561) 655.2896 office@visualevidence.org
Phone: (561) 655-2855
EFTA01103301
DataSet-10
Unknown
1 pages
IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454MOC
STATE OF FLORIDA
vs. NOTICE OF DEPOSITION
JEFFREY EPSTEIN,
Defendant. STATE OF FLORIDA • PALM BEACH Cittnir
I hereby certify that the
foregoing is a true copy
of the record In qy office.
TO: Lanna Belohlavek, Esquire
Office of the State Attorney
401 N. Dixie Hwy
' co
West Palm Beach, Florida 33401 By i
)•rn 0
7,7
PLEASE TAKE NOTICE that pursuant to the Florida es of ug that ichl
March 24. 2008 beginning at the hour of 1:30 P.M. at the Palm Beach Coun0 roirtkouse.X
Floor. 205 North Dixie Highway. West Palm Beach. Florida 33401: •
(-.)En:cc-, :
g -o M
=
before Consor & Associates who is authorized by law to take depositions in the SIDAFif FWida, the
Plaintiffs will, upon oral examination, take the deposition of the following llama Cigelephone, to
wit: 711--:=
fl •
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court.
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael R. Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 171° day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
Wes Palm ch, Florida 33401
(56 L 65'-83
56183. 91
A. GOLDBERGER, ESQUIRE
Fl icla Bar No. 262013
Lk,
MM15-STATE CASE-000187
3501.222-030
CONFIDENTIAL Page I of I
EFTA_00075078
EFTA01248829
DataSet-10
Unknown
1 pages
From: ==la
To: Chester Brewer deposition...he says he thought it was
by Skype though...is this true?
thanks!
Assistant to Jeffrey Epstein
EFTA00354439
DataSet-10
Unknown
1 pages
Date: Wed, 22 Sep 2021 8:45:45 PM (UTC)
Sent: Wed, 22 Sep 2021 8:45:44 PM (UTC)
Subject: Sandra Townsend
From:
To:
Sandra Townsend called. She has a copy of the deposition of
3526-002
Page I of I
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009665
EFTA00159472