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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
v. No. 17 Civ. 00616 (1OK)
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
Y GROFF and
Defendants.
PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION
OF JEFFREY EPSTEIN
PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil
Procedure, counsel for Plaintiff, will take a videotaped deposition of the
Defendant as set forth below:
NAME: Jeffrey Epstein
DATE AND TIME: October 12, 2018 at 10:00 a.m.
LOCATION: Atterbury Goldberger & Weiss, P.A.
One Clearlake Centre
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401
The videotaped deposition will be taken upon oral examination before Magna Legal
Services, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
1
EFTA00808194
The video operator shall be provided by Magna Legal Services. This deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the rules of this Court.
Dated: September 26, 2018.
BOLES SCHILLER FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller Flexner LLP
Bradley J. Edwards, Esq. (Pro Hac Vice)
Stanley Pottinger, Esq.
EDWARDS POTTINGER LLC
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
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
EFTA00808195
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 WITNESS
JEFFREY EPSTEIN via Email to the following counsel of record.
Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
Scott J. Link
LINK & ROCKENBACH PA
Counselfor Jeffrey Epstein, and Lesley Groff
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
Counselfor Ghislaine Maxwell
By: /s/ Sigrid McCawley
Sigrid McCawley
3
EFTA00808196
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2 pages
From:
Sent: Monde , Ma 19, 2014 8:50 PM
To:
Cc: jeevacation@gmail.com;
Subject: RE: Annette Siegal Estate
Martin
I am in a deposition all day tomorrow.
Jim
Original Message
From: Martin B. O'Connor II [mailto
Sent: Monday, May 19, 2014 4:49 PM
To: George, James R. (Shld-FTL-LT)
Cc: ; jeevacation@gmail.com; Pat Zwarycz
Subject: Re: Annette Siegal Estate
lets get jeffrey's number and call him in am pleased to take lead jeff-good=at 10? ok for you Jim?
thx
m
Sent from my iPad
> On May 19, 2014, at 4:10 PM, wrot=:
> Peggy
> I am happy to speak with Jeffrey at his convenience.
> My number
> Jim
> Sent from my iPhone
» On May 19, 2014, at 7:02 AM, "j: .=om> wrote:
» Jim...could you please call my friend, mentor, adviser Jeffrey Epstein a=d just fill him in....and/or send an email to
date.
» I hope this email serves as permission to do so.
» Peggy Siegal.
» Sent via BlackBerry by AT&T
> If you are not an intended recipient of confidential and privileged infor=ation in this email, please delete it, notify us
immediately at postmaster=gtlaw.com, and do not use or disseminate such information. Pursuant to IR= Circular 230,
EFTA_R1_01762109
EFTA02583723
any tax advice in this email may not be used to avoid tax p=nalties or to promote, market or recommend any matter
herein.
conversation-idgkey>
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date-last-viewed
0
date-received
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flags
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2
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EFTA_R1_01762110
EFTA02583724
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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 515 N. Flagler Drive
Suite 400
West Palm Beach, FL 33401
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 conec.t copy of this Notice was mailed this (Q
day of August, 2009 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD--KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) -1401
B
Fl. Bar No.: 089737
EFTA00599410
IN THE CIRCUIT COURT
OF THE
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 One Penn Plaza, Ste 471
New York, NY 10119
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 of this Notice was mailed this CO
day of August, 2009 to Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUV1N, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 5151400
(56 401
Spencer T. uvin,
Fl. Bar No.: 089737
EFTA00599411
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:
PATE AND TIME: LOCATION:
August 18, 2009 Esquire Court Reporters
11:00 AM One Penn Plaza
Suite 4715
New York, NY 10119
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 of this Notice was faxed and mailed
this f day of August, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400,
West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400,
West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive,
Suite 400, West Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 POA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 5 1
B 1%.
Spencer . Kuvm, Esq.
Florida Bar No: 089737
EFTA00599412
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 Atterbury, Goldberger, Weiss
do Burman, Critton, Luther, 10:00 AM 250 S. Austrailian Ave S
& Coleman LLP Suite 1400
WPB, FL 33401
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., 250 S Australian Ave. Ste 1400, West Palm Beach, FL 33401; Robert
Critton, Esq., Burman, Critton, Luttier & Coleman, LLP, 515 N. Flagler Dr. Ste 400, West Palm
Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 515-1401
By:
Cc: Pleasanton Greenhill Florida Bar No: 089737
Visual Evidence
EFTA00599413
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
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 Cartaga, PA
1601 Forum Place
Suite 1110
West Palm Beach, FL 33401
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 mailed this 6, day
of August, 2009 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, 515 North Flagler Drive, Suite 400, West
Palm Beach, FL 33401, Douglas McIntosh, EsqJCamille Blanton, Esq., 1601 Forum Place, Suite
1110, West Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 515-1401
By: 4 ,"
Spend T.
Florida Bar No: 089737
Cc: Pleasanton Greenhill
Visual Evidence
EFTA00599414
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 5701 North High St Edwards, cross
102 no notice yet Suite 300 notice by
Worthington, OH Josefsberg,
614-431-1344 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 One Penn Plaza Edwards, cross
Doe 102 By video Suite 4715 notice by
B.B. New York, NY10019 Josefsberg, by BB
U.S.Legal
- same - 8/18/09 11:00a.m - same - - same -
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 One Penn Plaza
Suite 4715
New York, NY10019
B.B. Jeffrey Epstein 9/02/09,10:00a.m Atterbury,Goldberger - same -
By video 250 S.AustralianAve.S
Suite 1400
West Palm Beach, FL
B.B. 9/21/09,1:00 p.m McIntosh Sawran - same -
By video 1601 Forum Place
Suite 1110
West Palm Beach,FI
EFTA00599415
DataSet-10
Unknown
134 pages
648
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and PAUL G.
CASSELL,
Plaintiffs,
VS.
ALAN M. DERSHOWITZ,
Defendant.
VIDEOTAPE CONTINUED DEPOSITION OF
ALAN M. DERSHOWITZ
VOLUME 5
Pages 648 through 781
Wednesday, January 13, 2016
9:04 a.m. - 11:59 a.m.
Tripp Scott
110 Southeast 6th Street
Fort Lauderdale, Florida
Stenographically Reported By:
Kimberly Fontalvo, RPR, CLR
Realtime Systems Administrator
EFTA01138026
649
1 APPEARANCES:
2
On behalf of Plaintiffs:
3
SEARCY, DENNEY, SCAROLA
4 BARNHART & SHIPLEY, P.A.
2139 Palm Beach Lakes Boulevard
5 West Palm Beach, Florida 33402-3626
BY: JACK SCAROLA, ESQ.
6
7
8 On behalf of Defendant:
9 COLE, SCOTT & KISSANE, P.A.
Dadeland Centre II - Suite 1400
10 9150 South Dadeland Boulevard
Miami, Florida 33156
11 BY: THOMAS EMERSON SCOTT, JR., ESQ.
12 BY: STEVEN SAFRA, ESQ. (Via phone)
13 --and
14 SWEDER & ROSS, LLP
131 Oliver Street
15 Boston, MA 02110
BY: KENNETH A. SWEDER, ESQ.
16
17 --and--
18 WILEY, REIN
17769 K Street NW
19 Washington, DC 20006
BY: RICHARD A. SIMPSON, ESQ.
20
21
22
23
24
25
EFTA01138027
650
1 APPEARANCES (Continued):
2
3 On behalf of Jeffrey Epstein:
4 DARREN K. INDYKE, PLLC
575 Lexington Ave., 4th Fl.
5 New York, New York
BY: DARREN K. INDYKE, ESQ. (Via phone)
6
7 On behalf of
8 BOIES, SCHILLER & FLEXNER, LLP
401 E. Las Olas Blvd., Ste. 1200
9 Fort Lauderdale, Florida 33301
BY: SIGRID STONE MCCAWLEY, ESQ.
10
11
12 ALSO PRESENT:
13 Edward J. Pozzuoli, Special Master
14 Sean D. Reyes, Utah Attorney General Office
15 Marcy Martinez, Videographer
16
17
18
19
20
21
22
23
24
25
EFTA01138028
651
1 INDEX
2
3
Examination Page
4
5 VOLUME 5 (Pages 648 - 781)
6
7 Certificate of Oath 778
Certificate of Reporter 779
8 Read and Sign Letter to Witness 780
Errata Sheet (forwarded upon execution) 781
9
10 PLAINTIFF EXHIBITS
11
12 No. Page
13 25 Transcript from Don Lemon Interview 689
14
15
16
17
18
19
20
21
22
23
24
25
EFTA01138029
652
1 Thereupon, the proceedings continued at 9:04 a.m.
2 VIDEOGRAPHER: Are now on the video
3 record. This is the 13th day of January, 2016.
4 The time is 9:04 a.m. This is the videotaped
5 deposition of Alan Dershowitz in the matter of
6 Bradley Edwards and Paul Cassell versus Alan
7 Dershowitz.
8 My name is Marcy Martinez. I am the
9 videographer representing Above & Beyond
10 Reprographics. Will the attorneys please
11 announce their appearances for the record.
12 MR. EDWARDS: Sure. On behalf of the
13 plaintiff today Brad Edwards, Jack Scarola,
14 Brittany Henderson and Paul Cassell.
15 MR. SIMPSON: On behalf of the defendant
16 and the witness, Richard Simpson, and Thomas
17 Scott will be joining. He just walked in.
18 MS. McCAWLEY: On behalf of nonparty
19 , Sigrid McCawley and my
20 colleague Meredith Schultz from Boies, Schiller
21 & Flexner.
22 MR. INDYKE: On behalf of Jeffrey Epstein,
23 Darren Indyke.
24 SPECIAL MASTER POZZUOLI: Ed Pozzuoli as
25 the special master.
EFTA01138030
653
1 MR. SIMPSON: Is there anyone else on the
2 phone?
3 MR. MAISEL: Yeah, this is Nicholas
4 Maisel.
5 THE COURT REPORTER: Would you raise your
6 right hand, please?
7 Do you swear or affirm that the testimony
8 you are about to give will be the truth, the
9 whole truth, and nothing but the truth?
10 THE WITNESS: I do.
11 MR. SCAROLA: Nick, would you announce the
12 capacity in which you're appearing, please.
13 MR. MAISEL: Special research assistant
14 for Alan Dershowitz.
15 MR. SCAROLA: Thank you.
16 MR. EDWARDS: Are we ready?
17 SPECIAL MASTER POZZUOLI: Go ahead.
18 BY MR. EDWARDS:
19 Q. Mr. Dershowitz, in January of 2015, when
20 you made the statements that Paul Cassell and Brad
21 Edwards participated in the fabricating of the
22 allegations that were made against you, what
23 information or evidence did you have in your
24 possession at that time to support those statements?
25 MR. SIMPSON: Object to the form as overly
EFTA01138031
654
1 general. You may answer.
2 A. As soon as the allegations were made
3 against me, I received a series of phone calls and
4 people approached me at various events and they
5 warned me about the reputation of Bradley Edwards.
6 They told me that he had, in their view,
7 participated in a major fraud with a man named
8 Rothstein, that he should be in jail for the
9 Rothstein events.
10 I received a phone call saying that he had
11 fabricated evidence when he was a prosecutor and
12 that he had knowingly failed to investigate police
13 fabrication of evidence in a case. Generally was
14 warned about the terrible reputation that
15 Mr. Edwards had.
16 I also received phone calls telling me
17 that Mr. Cassell was a zealot, that he had used me
18 in class as a whipping -- as a kind of an object of
19 hate and painted me as a liberal supporter of the
20 exclusionary rule and opponent of the death penalty,
21 and that he had no concern for the truth when it
22 came to his zealotry on behalf of alleged victims.
23 The calls were just -- the people who told
24 me this were just -- there were so many of them that
25 it was amazing to me.
EFTA01138032
655
1 And I knew, of course, that I had never
2 met -- had no contact with I knew
3 that she was lying. I read her deposition, and as
4 an experienced lawyer with 50 years of experience,
5 it was absolutely clear to me that no lay person
6 with her lack of education could have written that
7 deposition.
a I sought the advice of friends and others
9 with experience who confirmed the view that that
10 affidavit clearly had to have been written by
11 lawyers and certainly drafted by lawyers; the level
12 of detail, the structure of the sentences, all of
13 which led me conclusively to the belief that the
14 lawyers had written this affidavit.
15 I suspected from the very beginning that
16 this was part of an extortion plot in order to
17 obtain money. I later learned many, many, many
18 facts.
19 MR. EDWARDS: I object and move to strike
20 as nonresponsive and that the question calls
21 for information in his possession in January of
22 2015. I would ask for a ruling on that.
23 A. I'm providing that, but I'm giving the
24 context.
25 SPECIAL MASTER POZZUOLI: Denied. Move
EFTA01138033
656
1 forward.
2 A. Okay. I knew that there was a financial
3 motivation here. I also knew that Cassell and
4 Edwards had lied when they said they were
5 representing in a pro bono basis.
6 I had been informed repeatedly that they
7 were in it for the money and that they expected to
a earn a lot of money from representing her and others
9 in this case and that they pretended to be pro bono
10 lawyers when they were, in fact, money-grubbing,
11 money-hungry lawyers who had earned a very
12 substantial amount of money already on these cases
13 and were expecting to earn more money.
14 Let me think of what other information I
15 had.
16 SPECIAL MASTER POZZUOLI: At the time of
17 the question.
18 A. At the time of my statements, right.
19 It's just inconceivable to me that this
20 uneducated woman could have come up with this story
21 on her own.
22 I understood the motives of the lawyers,
23 and I was convinced, therefore, it was my opinion
24 based on my experience, in fact, that she could not
25 have done this by herself and that she had to have
EFTA01138034
657
1 worked in coordination with her lawyers.
2 Her lawyers were also at that point
3 claiming that the story should be believed because
4 of who they were. Mr. Cassell, in my view,
5 unethically signed his pleading with the University
6 of Utah imprimatur, suggesting that he was a State
7 actor, suggesting that he acted on behalf of his
8 university, something I would never do and I've
9 stopped clients from doing. When I represent
10 people, I represent them on my own behalf, not on
11 behalf of any university.
12 The very fact that the Attorney General of
13 Utah was here yesterday indicates that he may very
14 well be a State actor and subject to the rules of
15 State action rather than individual action.
16 SPECIAL MASTER POZZUOLI: That portion I
17 will strike. That sentence.
18 A. Sorry.
19 BY MR. EDWARDS:
20 Q. Okay.
21 A. I'm not finished.
22 SPECIAL MASTER POZZUOLI: Is there any
23 other information that you haven't touched
24 on --
25 THE WITNESS: I'm trying to --
EFTA01138035
658
1 SPECIAL MASTER POZZUOLI: -- as of, what,
2 January?
3 MR. EDWARDS: January of 2015.
4 THE WITNESS: Oh, yes.
5 MR. SCAROLA: January 4.
6 MR. EDWARDS: January 4, 2015.
7 A. Okay, that's the question. But, of
8 course, I made a series of statements that continued
9 beyond January 4, and they always took into account
10 new developments and new information that I had.
11 I was also aware that Mr. Cassell was
12 promoting himself as a former federal judge and
13 using his status and imprimatur in a false effort to
14 try to add credibility to the story.
15 And I did not make -- this is very
16 important to this. I did not make a single call to
17 a single newspaper or single television station, to
18 my knowledge, or a single newspaper. I was
19 constantly responding.
20 MR. SCAROLA: That's not responsive.
21 A. Excuse me. In the last deposition --
22 SPECIAL MASTER POZZUOLI: No, no.
23 A. -- there was an interruption by
24 Mr. Scarola that I want to put on the record.
25 SPECIAL MASTER POZZUOLI: No, no, no, no,
EFTA01138036
659
1 no, no, no. No. Respond to the question that
2 was answered and go ahead because I haven't
3 heard any objection yet.
4 MR. EDWARDS: I'm objecting to all of this
5 as being nonresponsive to the question.
6 SPECIAL MASTER POZZUOLI: Is there
7 anything else that you would like to add to the
8 answer?
9 THE WITNESS: Yes.
10 A. When the newspapers called me, they all
11 asked me the following question --
12 SPECIAL MASTER POZZUOLI: Was this in
13 January?
14 A. This was in January.
15 BY MR. EDWARDS:
16 Q. The question on the table is --
17 SPECIAL MASTER POZZUOLI: Hang on one
18 second.
19 A. I'm going to tell you.
20 MR. EDWARDS: What information that
21 Mr. Dershowitz had in January 4, 2015, when he
22 made the statement that Paul Cassell and Brad
23 Edwards fabricated the allegations against him.
24 MR. SIMPSON: The question was about in
25 January of 2015.
EFTA01138037
660
1 SPECIAL MASTER POZZUOLI: That's what it
2 was. That was the original question, which is
3 why he was afforded a tremendous amount of
4 latitude.
5 MR. EDWARDS: Understood.
6 A. And I got continuing information all
7 through January and amended my statements as
8 consistent with the information that I got.
9 The newspapers called me. They all said
10 to me, why would anybody make a false allegation if
11 he's a former Federal judge, if he's a professor, if
12 he's a distinguished trial lawyer?
13 Clearly the -- on the 4th of December,
14 talking about that day, that's the day on which
15 Mr. Cassell wrote to ABC
16 BY MR. EDWARDS:
17 Q. January.
18 A. January 4, 2015, that's the date on which
19 Mr. Cassell wrote to ABC News asking them to
20 publicize his client's story and to -- and again
21 making it clear to ABC who he was and what he -- and
22 who he had been and what offices he had held.
23 And so it was clear to me at that point,
24 and through January it became clearer and clearer
25 that she could not have done this on her own, that
EFTA01138038
661
1 she had to have sat with her lawyers and concocted
2 this story, added the kind of detail to the story
3 that would make a lie seem plausible and credible.
4 And I think that any reasonable lawyer reading that
5 affidavit would have come to exactly the same
6 conclusion that I came to.
7 SPECIAL MASTER POZZUOLI: Okay.
8 BY MR. EDWARDS:
9 Q. Mr. Dershowitz, when you first made the
10 statement on January 4, 2015 that Mr. Cassell and
11 Brad Edwards had participated in the fabrication of
12 these allegations, did you have before you any
13 affidavit or, as you have repeatedly called it,
14 deposition of
15 MR. SIMPSON: Object to the form. It's
16 referring to a specific statement that has not
17 been identified for the witness.
18 A. Affidavit of What I had
19 was the lawyers' statements that were included in
20 the Complaint, which they then sought to publicize
21 all around the world and got more than a thousand
22 newspapers to cover the story, every television
23 station in the world, every radio station virtually
24 in the world, based on what they themselves had
25 written, actually gives me even a greater basis,
EFTA01138039
662
1 because it wasn't at that point based on her
2 affidavit, it was based on what the lawyers had
3 said.
4 MR. EDWARDS: I object. Can I have the
5 question read back. I'm lost as to what the
6 question is anymore.
7 SPECIAL MASTER POZZUOLI: Ask -- reread
8 the question.
9 COURT REPORTER: "Mr. Dershowitz, when you
10 first made the statement on January 4, 2015
11 that Mr. Cassell and Brad Edwards had
12 participated in the fabrication of these
13 allegations, did you have before you any
14 affidavit or, as you have repeatedly called it,
15 deposition of ."
16 BY MR. EDWARDS:
17 Q. Did you?
18 SPECIAL MASTER POZZUOLI: So that's the
19 question. Answer that question only.
20 MR. SCAROLA: Move to strike everything
21 else he's said.
22 A. On January 4th, to my memory, I did not
23 refer to a deposition or to whatever other word you
24 used -- what was the word?
25 MR. SIMPSON: Affidavit.
EFTA01138040
663
1 MR. EDWARDS: Affidavit.
2 A. -- if I hadn't seen it at that point. I
3 don't remember the exact day when her affidavit came
4 in. I referred obviously to the pleadings. That
5 was the allegation, the allegation in the pleadings.
6 So if I said that you and Cassell sat and
7 helped her make it up, it was based on -- at that
8 point in time, based on you and her, primarily you
9 and Cassell, because she didn't submit -- it wasn't
10 an affidavit at that point.
11 It was your words, you, that were accusing
12 me of these heinous crimes without any basis. So I
13 surely had a basis on January 4th of attributing it
14 to you because it was your signature on the
15 SPECIAL MASTER POZZUOLI: Hold on a
16 second. So I understand, the question is what
17 did you have on January 4th --
18 MR. EDWARDS: -- 2015 to support that
19 statement.
20 SPECIAL MASTER POZZUOLI: Just answer that
21 question first and then you can explain, but --
22 A. With due respect, Your Honor, I think the
23 question was, did you have the affidavit in front of
24 you.
25
EFTA01138041
664
1 BY MR. EDWARDS:
2 Q. Right. Okay. Did you have the affidavit
3 or deposition of on that day?
4 A. To my recollection, I did not. I had only
5 your characterization of the accusation which you
6 were making against me.
7 Q. And in your experience as an attorney,
8 isn't it common knowledge that attorneys drafting
9 complaints or pleadings take the word of the client
10 to form the basis of that Complaint or pleading?
11 A. No, it's not common knowledge. It's
12 common knowledge that unethical lawyers of the kind
13 that your reputation told me you were help the
14 clients
15 MR. EDWARDS: I object. Move to strike as
16 nonresponsive.
17 SPECIAL MASTER POZZUOLI: That, I am going
18 to strike. Try -- try to answer the question.
19 A. But I think the generic answer is ethical
20 lawyers -- let me put it this way, ethical lawyers
21 should not elaborate on what a client tells them in
22 an affidavit.
23 In my experience, there's a continuum.
24 Many, many lawyers, when they see a statement by a
25 client, they'll say, no, no, no, no, could you
EFTA01138042
665
1 please elaborate on that. You say you had sex with
2 him. Was it one time? Was it two times? Could it
3 have been six times? Could it have been on the
4 airplane? Could it have been -- et cetera.
5 So I think it's a continuum of the way
6 lawyers work with clients. The most ethical lawyers
7 don't change what a client says. They word for word
8 repeat what the client says.
9 The most unethical lawyers will put all of
10 their own thoughts, words, ideas if it strengthens
11 their position and strengthens their case.
12 From what I had been -- from the
13 information I knew at that time, I put you on the
14 extreme unethical end of the continuum.
15 SPECIAL MASTER POZZUOLI: That wasn't the
16 question, so 1 will strike the last sentence.
17 We need to get focused on answering the
18 question, so please try to do that.
19 A. Okay, I will do that.
20 BY MR. EDWARDS:
21 Q. When you first made the statements that
22 Paul Cassell and Brad Edwards fabricated the
23 allegations --
24 A. Would you read me the statement that you
25 say I made on January 4th so I can understand what
EFTA01138043
666
1 you're saying?
2 Q. Do you deny making the statement that Brad
3 Edwards and Paul Cassell fabricated the allegations
4 against you?
5 A. I remember making a series of statements
6 over time. I do not remember what I said on
7 January 4th. In order to ask me what I had at the
8 time I made the statement, I need to know with
9 precision the exact statement you are referring to
10 and the exact date. I think that's a fair request.
11 Q. We'll get that for you. It would be
12 easier had you made less statements, but we'll sift
13 through them.
14 A. If would be easier if you had called
15 MR. SIMPSON: There's no question. Object
16 to the sidebar comments.
17 SPECIAL MASTER POZZUOLI: Yes, let's --
18 BY MR. EDWARDS:
19 Q. What are the names -- please list for me
20 all of the names of the people who told you that --
21 in quotes -- Brad Edwards was -- participated in a
22 major fraud with Rothstein. Names of people.
23 MR. INDYKE: Objection based upon
24 attorney-client, work product, common interest.
25 SPECIAL MASTER POZZUOLI: Well, okay.
EFTA01138044
667
1 MR. INDYKE: Instruct Alan not to answer
2 to the extent it would disclose communications
3 of who made those --
4 SPECIAL MASTER POZZUOLI: Objection noted.
5 You can answer it.
6 A. What framework are you giving me in terms
7 of time?
8 SPECIAL MASTER POZZUOLI: In January.
9 BY MR. EDWARDS:
10 Q. You told me that before you made these
11 statements, one of the things that you had in your
12 possession was a series of phone calls, "a bunch of
13 people called me" --
14 A. That is right. That's true.
15 Q. -- "and told me Brad Edwards participated
16 in major fraud with Rothstein." That's the first
17 question I want answered. What are the names of
18 those people?
19 A. A number of them who called me were ones
20 who volunteered --
21 MR. SCAROLA: That's not a response to the
22 question.
23 BY MR. EDWARDS:
24 Q. What are the names?
25 SPECIAL MASTER POZZUOLI: Stop, stop,
EFTA01138045
668
1 please, please, please.
2 A. I'm invoking the privilege, if you would
3 allow me, please. A number of those who called me
4 called me in tandem to volunteer to be my lawyer.
5 I'll give you an example.
6 SPECIAL MASTER POZZUOLI: No, no, hang on.
7 A. I can't name this person because he called
8 to give me legal advice, and I -- he gave me that
9 information as part of his legal advice.
10 BY MR. EDWARDS:
11 Q. I'm not asking if one of the lawyers who
12 represented you and you have an attorney-client
13 privilege with has shared with you some information
14 that they believe to be the case.
15 I'm asking if you are using as support for
16 your statement that certain people told you and you
17 relied upon this -- and the particular "this" at
18 this point is that Brad Edward participated in a
19 major fraud with Scott Rothstein -- I want to know
20 the names of those people that you are relying upon
21 to test veracity of that statement, please. Names
22 of people.
23 A. One of the names was of a person who I was
24 seeking legal representation from, and it was part
25 of my conversation with him regarding legal
EFTA01138046
669
1 representation.
2 MR. SCAROLA: That's not a name.
3 MR. EDWARDS: I'm sorry, I object and I
4 ask --
5 A. If I give you the name
6 SPECIAL MASTER POZZUOLI: I do think you
7 have to give the name.
8 A. Okay. The name of that person would be
9 David Markus.
10 BY MR. EDWARDS:
11 Q. Okay.
12 A. And he told me to check the docket --
13 MR. SIMPSON: Just the question.
14 BY MR. EDWARDS:
15 Q. When did David Markus call you to tell you
16 that he knew or believed that Brad Edwards
17 participated in a major fraud with Rothstein?
18 A. Within days. Within probably a day or
19 two.
20 Q. Did he tell you what it was that formed
21 the basis for that statement that he made to you
22 that you so relied upon?
23 A. I don't recall.
24 Q. Was it more than the fact that your
25 client, Jeffrey Epstein, had filed a lawsuit making
EFTA01138047
670
1 those allegations?
2 A. I don't think he was aware that Jeffrey
3 Epstein had made an allegation of that kind.
4 Q. At the time when David Markus called you
5 to tell you that Brad Edwards participated in a
6 major fraud with Rothstein, did you already --
7 A. That's not
8 Q. -- have or know that Scott Rothstein had
9 testified under oath about that specific subject
10 matter?
11 A. Well, I can't imagine that you're relying
12 on Scott Rothstein's credibility.
13 Q. I'm asking, did you know?
14 MR. SIMPSON: Just answer the question.
15 BY MR. EDWARDS:
16 Q. Yes or no?
17 SPECIAL MASTER POZZUOLI: Did you know?
18 A. I did not know.
19 BY MR. EDWARDS:
20 Q. Did you know at that point in time that
21 the Complaint that was filed by your client, Jeffrey
22 Epstein, against Brad Edwards, making those exact
23 allegations, had been dismissed at the stage -- at
24 the point in time when David Markus was making these
25 statements to you that you so relied upon?
EFTA01138048
1 MR. INDYKE: Same objection, same
2 instruction.
3 SPECIAL MASTER POZZUOLI: He's --
4 MR. EDWARDS: Calls for a yes or no
5 SPECIAL MASTER POZZUOLI: He's only asked
6 if you aware that the case was dismissed at
7 that time.
8 A. I don't think I was. But a case being
9 dismissed does not mean the allegation isn't true.
10 SPECIAL MASTER POZZUOLI: I understand,
11 but --
12 BY MR. EDWARDS:
13 Q. Okay. In addition to David Markus, can
14 you please complete this list of people that you
15 testified called you to tell you specifically that
16 Brad Edwards participated in a major fraud with
17 Rothstein?
18 A. So, I spoke several times during that
19 period of time at various events. And people --
20 lawyers came over to me and told me --
21 Q. I'm not asking where. Who? What are the
22 names?
23 A. I can tell you one of them --
24 SPECIAL MASTER POZZUOLI: He's trying to
25 be -- I would allow him to answer it. He's
EFTA01138049
672
1 trying to be responsive to the question.
2 Please proceed.
3 A. One of them was a former president or
4 chairman or at least member of the Florida Bar
5 committee who warned me about you.
6 BY MR. EDWARDS:
7 Q. Does he have a name?
8 A. I don't remember his name. I don't
9 remember his name, no. Of course he has a name, but
10 I don't remember his name.
11 Another was -- I mean -- just hard to
12 pinpoint names, but it was something that was
13 clearly in my mind that so many people were telling
14 me -- telling me to look into the case of Rothstein,
15 telling me that you were his protege.
16 Q. Okay. Is it true, then, that you have the
17 name of one person who you can identify told you
18 that Brad Edwards participated in a major fraud with
19 Rothstein?
20 A. I was also aware, of course, of the
21 Complaint that had been filed against you. And that
22 was one -- I mean, I can't comment on that because
23 of lawyer-client privilege.
24 SPECIAL MASTER POZZUOLI: Listen to the
25 question, Professor. Go ahead.
EFTA01138050
673
1 BY MR. EDWARDS:
2 Q. Is it now your testimony that you can only
3 provide me with one name of one human being that
4 called you and told you Brad Edwards participated in
5 a major fraud with Rothstein?
6 A. I will try to think of others.
7 Probably -- I may have some notes of others. I will
8 call around and find out whether my memory is
9 correct or not.
10 MR. SIMPSON: Professor --
11 A. But I don't want to mention names without
12 being sure.
13 MR. SIMPSON: Just do you recall, as you
14 sit here, the names?
15 A. And right now, I don't recall names, other
16 than a general discussion with my lawyers. And in
17 the general discussion with my lawyers -- and I
18 don't want to get into it --
19 SPECIAL MASTER POZZUOLI: Then don't do
20 it.
21 BY MR. EDWARDS:
22 Q. Are you relying upon the statements from
23 your lawyers to support this allegation that the
24 basis of your statement that Brad Edwards
25 participated in the fabrication of the allegations
EFTA01138051
6/4
1 against you was a list of people told you
2 Brad Edwards participated in a major fraud with
3 Rothstein; and, if so, I want to know the names of
4 those lawyers that you are using to support that
5 allegation?
6 MR. SIMPSON: Well, we have asserted
7 privilege as to communications with those who
8 represented you. Please don't disclose that.
9 MR. SCAROLA: Respectfully -- pardon me --
10 the witness is the possessor of that privilege.
11 He cannot make a statement disclosing the
12 content of the communications that he is
13 relying on and then he himself assert a
14 privilege to refuse to provide further
15 information with regard to the statement that
16 he has made. We would request a ruling on the
17 record as to whether there has already been a
18 waiver.
19 A. What I said, of course, was that
20 SPECIAL MASTER POZZUOLI: Excuse me. Hang
21 on a second.
22 MR. SCAROLA: We're requesting a ruling on
23 the record as to whether there has been a
24 waiver as a consequence of what has already
25 been stated.
EFTA01138052
675
1 MR. SIMPSON: He did not testify that
2 he -- we went through long questions and
3 answers in response to Mr. Edwards' questions.
4 He did not say he was relying on what his
5 lawyers told him in this case.
6 SPECIAL MASTER POZZUOLI: I think that
7 there is -- let me say this: I think the
8 question was from Mr. Edwards whether he relied
9 on statements from his lawyers. I do think
10 that you have to answer that question.
11 A. I would say that the statements from my
12 lawyers played a small role. The larger role
13 BY MR. EDWARDS:
14 Q. I want to know about that small role.
15 SPECIAL MASTER POZZUOLI: Hang on one
16 second. So now proceed.
17 BY MR. EDWARDS:
18 Q. Sure. I would like to know whose
19 statements it was that played a small role in your
20 belief that Brad Edwards fabricated cases based on
21 the statements that they made to you that
22 Brad Edwards participated in a major fraud with
23 Rothstein. What are the name of those individuals?
24 A. It's a complicated question here. So
25 there are three issues that I understand. One, what
EFTA01138053
676
1 was the basis for my belief that you had fabricated
2 along with Mr. Cassell --
3 Q. No, I'm asking for names of human beings.
4 SPECIAL MASTER POZZUOLI: No, let me stop
5 you. My understanding of your testimony was
6 that whatever you received -- whatever
7 information you received from your lawyers
8 played a small role. That's what you testified
9 to.
10 THE WITNESS: That's right.
11 SPECIAL MASTER POZZUOLI: Correctly,
12 Mr. Edwards then followed up on that question
13 and said, let's go into that small role.
14 THE WITNESS: Okay.
15 SPECIAL MASTER POZZUOLI: So now . . .
16 BY MR. EDWARDS:
17 Q. What are the names of those people that
18 gave you this information that played a small role
19 in --
20 A. In what?
21 Q. in your belief that Brad Edwards had
22 participated in a major fraud with Rothstein which
23 somehow furthered your belief that Brad Edwards and
24 Paul Cassell fabricated the allegations against you?
25 So I'm asking for names of the people.
EFTA01138054
677
1 A. So my best recollection, and it's now over
2 a year, is that that was a subject of conversation
3 with David Markus. It was also the subject of
4 conversation with --
5 MS. McCAWLEY: I'm sorry, I didn't hear
6 that. If he's talking about conversations
7 MR. EDWARDS: He said Davis Markus.
8 MS. McCAWLEY: I'm sorry. I couldn't
9 hear.
10 A. Another lawyer -- other people sent me
11 newspaper clippings.
12 SPECIAL MASTER POZZUOLI: No, no, no.
13 A. Lawyer. Okay. The other lawyer who told
14 me about that was a lawyer named David Efron.
15 MR. SCAROLA: First of all, make sure the
16 list is complete, and then you want to know
17 every one.
18 BY MR. EDWARDS:
19 Q. Is that it? David Markus, David Efron?
20 A. Those are the two I remember offhand.
21 Plus, as I said, when I spoke I spoke
22 at several events in January --
23 Q. Right now --
24 A. -- and lawyers came -- people
25 lawyers --
EFTA01138055
678
1 SPECIAL MASTER POZZUOLI: Let me stop you.
2 BY MR. EDWARDS:
3 Q. Let me get to the next question.
4 A. Yes.
5 SPECIAL MASTER POZZUOLI: Let me ask the
6 witness, the question is limited to --
7 MR. EDWARDS: Yes, the lawyers who played
8 a small role.
9 SPECIAL MASTER POZZUOLI: The small role
10 around the lawyers, and I think the followup
11 question was, you've mentioned a second lawyer,
12 is there anybody else on that list?
13 BY MR. EDWARDS:
14 Q. Yes.
15 A. Two lawyers, yes. The lawyers who came
16 over to me at the events that I spoke at.
17 Q. What are their names?
18 A. I don't know.
19 Q. How do you know that they're lawyers?
20 A. Because it was a lawyers' event. And they
21 were trial lawyers. This was all trial lawyers at
22 the event. Florida trial lawyers.
23 Q. You don't have the names of any of them;
24 is that right?
25 A. I can describe one of them as somebody who
EFTA01138056
679
1 came over to me and told me -- he may have given me
2 a card, which I conceivably may have at home, told
3 me that he was a former official of the Florida Bar
4 and was outraged at what had happened and told me to
5 please look into your background and then told me
6 about your background.
7 Q. Dade Markus, is he a former student of
8 yours?
9 A. Yes, yes.
10 Q. Did he have anything to do with the
11 investigation into the -- Scott Rothstein or any of
12 that?
13 A. I don't know.
14 Q. David Efron, did he have any inside
15 personal information into who was or who was not
16 culpable in any aspect of the fraud with Scott
17 Rothstein?
18 A. I don't know.
19 MR. SCAROLA: You want to know exactly
20 what they said.
21 BY MR. EDWARDS:
22 Q. Before we go to the next statement that
23 apparently formed your basis for believing that
24 Brad Edwards and Paul Cassell fabricated the
25 allegations against you, can you tell me exactly
EFTA01138057
680
1 word for word as you remember it what David Markus
2 and then what David Efron told you --
3 SPECIAL MASTER POZZUOLI: Let's start with
4 the first one.
5 BY MR. EDWARDS:
6 Q. -- what David Markus told you about the
7 participation of Brad Edwards in a fraud with
8 Rothstein?
9 MR. SIMPSON: We assert privilege to the
10 extent that it's someone who he was getting
11 legal advice from.
12 SPECIAL MASTER POZZUOLI: I'm going to
13 allow the question. You can answer over
14 objection.
15 A. All I can tell you is what the total
16 information I had at that point. I can't now, as I
17 sit here, separate out what Markus said, what Efron
18 said, what the lawyers who I met at the events said.
19 I can give you a totality of what the conclusion was
20 that was reached. Each of them contributed
21 something.
22 BY MR. EDWARDS:
23 Q. Where were you when you received this
24 communication from David Markus about his
25 understanding or belief that Brad Edwards
EFTA01138058
681
1 participated in a major fraud with Rothstein?
2 A. In my apartment, I suspect.
3 Q. Do you remember this?
4 A. I remember being in my apartment when the
5 story broke and getting call after call after call
6 from lawyers.
7 Q. Was this a telephone call with David
8 Markus --
9 A. Probably.
10 Q. -- or an in-person meeting?
11 A. It was -- well, I had both. I had both
12 with him. I had a telephone call and then we had a
13 meeting.
14 Q. And in this, did he describe to you what
15 support he had for this statement that he was making
16 to you regarding the involvement of Brad Edwards in
17 a major fraud with Rothstein?
18 MR. SCOTT: Objection, work product on
19 this whole line of questioning. He has the
20 name. If we're going to go beyond this, we
21 need a judicial ruling from the judge and you.
22 SPECIAL MASTER POZZUOLI: Well, I'm going
23 to allow the witness to answer it at this point
24 and overrule the objection without prejudice.
25 A. What is the question again?
EFTA01138059
682
1 SPECIAL MASTER POZZUOLI: Well, go back to
2 the question.
3 COURT REPORTER: "And in this, did he
4 describe to you what support he had for this
5 statement that he was making to you regarding
6 the involvement of Brad Edwards in a major
7 fraud with Rothstein?"
8 A. I'm sure he told me some information
9 involving his state of knowledge, but I can't
10 separate out now what different people told me. All
11 I remember is the totality of the conclusion that I
12 reached based on what they told me.
13 BY MR. EDWARDS:
14 Q. What specifically did he tell you, if you
15 remember?
16 MR. SCOTT: Same objection standing. I
17 just wanted to make sure we have a standing
18 objection.
19 SPECIAL MASTER POZZUOLI: I'll give you a
20 standing objection. I understand that piece.
21 If you don't remember, you don't remember or if
22 you can't describe it, rather than going
23 through again the generalities, so try to
24 answer his specific question.
25 A. Sure. Okay. The answer is I do remember
EFTA01138060
683
1 the generalities, but I don't remember the
2 particulars of that. I would be happy to try to
3 refresh my recollection.
4 MR. SCAROLA: We're going to take a short
5 break.
6 VIDEOGRAPHER: Going off the record. The
7 time is 9:38 a.m.
8 (Recess was held from 9:38 a.m. until 9:45 a.m.)
9 VIDEOGRAPHER: Going back on the record.
10 The time is 9:45 a.m.
11 BY MR. EDWARDS:
12 Q. Did David Markus say Brad Edwards
13 participated in a major fraud with Rothstein?
14 MR. SCOTT: Objection, work product and
15 privileged.
16 SPECIAL MASTER POZZUOLI: I'll overrule
17 the objection.
18 MR. SCOTT: I have a question. Are we
19 taking the position that he has to answer the
20 question now and pending an appeal to the
21 judge? Is that what we're doing?
22 SPECIAL MASTER POZZUOLI: Or -- I will
23 reserve your right --
24 MR. SCOTT: Because you reserved on all
25 their stuff yesterday.
EFTA01138061
684
1 SPECIAL MASTER POZZUOLI: I will reserve
2 on that, but I want him to answer the question
3 at this point. I believe that at this point,
4 given the inquiry and given the witness's
5 answers previously, that they've opened the
6 door, at least to this extent. But I will
7 reserve, but I want him to answer.
8 A. I will. I do not recall precisely what
9 David Markus or David Efron said. I do recall that
10 they -- to the best of my recollection, that they
11 both contributed to my general sense of what your
12 reputation was.
13 BY MR. EDWARDS:
14 Q. I want to only stick with David Markus and
15 then we'll move on to David Efron.
16 A. Okay.
17 Q. All right. Did David Markus say anything
18 along the lines of, close to, Brad Edwards
19 participated in a major fraud with Rothstein?
20 MR. SCOTT: Same objection.
21 A. My best recollection is that he said
22 something along those lines. He certainly said
23 something that led me to that conclusion.
24 BY MR. EDWARDS:
25 Q. Did he tell you to look into a court file
EFTA01138062
685
1 or did he tell you Brad Edwards participated in a
2 major fraud with Rothstein?
3 MR. SIMPSON: We have a continuing
4 objection on this, and also object to the form
5 of that one.
6 SPECIAL MASTER POZZUOLI: Yeah, well, the
7 form I'm not going to rule on, but the form is
8 awkward, at best.
9 MR. SIMPSON: We just want in the record
10 we have a continuing objection.
11 SPECIAL MASTER POZZUOLI: Yes.
12 BY MR. EDWARDS:
13 Q. I've heard two statements. One is that
14 David Markus said to look into a court file. And
15 the other I understood you to say is, David Markus
16 told me Brad Edwards participated in a major fraud
17 with Rothstein, which is what gave the support for
18 the statement that I ultimately made about
19 Brad Edwards participating in the fabrication of
20 these allegations.
21 So I'm trying to understand, did David
22 Markus tell you that Brad Edwards participated in a
23 major fraud with Rothstein?
24 SPECIAL MASTER POZZUOLI: You have a
25 continuing objection, but you can answer.
EFTA01138063
686
1 A. To the best of my recollection, it's more
2 than a year ago now, he told me facts that led me to
3 conclude that you had participated in a major fraud.
4 He told me, for example, that what
5 Brad Edwards -- that what Rothstein was selling were
6 fake Edwards cases made up by people who didn't
7 exist.
8 He told me -- I think it was he who told
9 me, but I can't be sure, that you were a protege,
10 that you had offices that were very close to each
11 other, that the fraud was very similar to what was
12
DataSet-10
Unknown
1 pages
From: J
To:
Subject: Re:
Date: Thu, 25 Oct 2018 18:44:20 +0000
Of course not
On Thu, Oct 25, 2018 at 2:42 PM wrote:
Did you write deposition against me!
In, 25 on. 2018 r. B 14:29, J leevacation@gmail.com>:
Are you receiving things from my address?
On Thu, Oct 25, 2018 at 1:58 PM wrote:
Killers: Prokhorov and Baibakov (plus all his people), Zampolli Paolo, Anna Konchakovskaya and all
people who work for them. Prokhorov has a lot to hide
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation®gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA01018593
DataSet-10
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80893CIV -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
Alan Dershowitz on, October 28, 2009, at 1:00 p.m., at:
Cambridge Court Reporters
675 Massachusetts Avenue
11th Floor
Cambridge, MA 02139
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
a Al-
by U.S. Mail and email transmission this I day of September, 2009 to all those on the
attached Service List.
EFTA01154679
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel: (954) 522-3456
Fax: (954) 527-8663
Email: bedwards rra-law.com
Ka BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Cambridge Court Reporters
EFTA01154680
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80893CIV —MARRS
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
CROSS-NOTICE OF TAKING
VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
MIR on, September 3, 2009, at 9:00 a.m., at:
Searcy Denney Scarola
Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
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 Q7 day of August, 2009 to all those on the
attached Service List.
EFTA00727550
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel: (954) 522-3456
Fax: (954) 527-8663
Email:
By:
EDWARDS, ESQ.
on a Bar No.: 542075
cc: Esquire Court Reports
EFTA00727551
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From:
To:
Subject: pstein, 'art
Date: Fri, 22 Jan 2010 16:56:12 +0000
Importance: Normal
Attachments: 20100104_Kuvin-M. Ltr001.pdf; 20100122_Kuvin_Ltr_re_Reiter_Deposition.wpd
Hi everyone. It is going to be an Epstein kind of day. Here is part 1.
A couple of weeks ago, I forwarded a letter that I received from partner), who
represents several of the Epstein victims, along with a proposed response. receive some comments back from
which I have incorporated.
Can -take a look and give me a final okay and I will get this out today? I have attached both Kuvin's
letter and my proposed response.
You will soon receive parts 2 and 3. Part 2 relates to a new letter from Roy Black and Part 3 relates to the Paul
Cassell/Brad Edwards hunt for the "Black Book."
Thank you.
Assistant U.S. Attorney
Ft Lauderdale, FL 33394
EFTA00213208
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From: "Lesley Groff" a>
To: leevacation@gmail.com>, a, a>
Subject: Fw: Jeffrey Epstein
Date: Sat, 18 Dec 2010 02:30:22 +0000
From:
To: Lesley Groff
Sent: Fri Dec 17 20:50:44 2010
Subject: Re: Jeffrey Epstein
I just finished my deposition and am running late for a dinner. Please let me know what time tomorrow will
work. I can be available around noon as that is 9am califomia time. My flight leaves around noon so i have some
time in the morning. Thanks.
Sent via BlackBerry by AT&T
From: "Lesley Groff' a>
Date: Fri 17 Dec 2010 15:27:33 -0500
To:
Subject: e yEpstein
Excellent. Thank you very much
From:
Sent: Friday, December 17, 2010 3:24 PM
To: Lesley Groff
Subject: Re: Jeffrey Epstein
I am in a deposition in califomia. I will call u on a break to coordinate a meeting. Thanks.
Sent via BlackBerry by AT&T
From: "Lesley Groff' a
Date: Fri, 17 Dec 2010 15:08:13 -0500
To: cz EM=I
Subject: Jeffrey Epstein
EFTA00649001
Hello Mr. Osber. Jeffrey Epstein would like to speak with you and asked if we could coordinate a time for the
two of you to speak today sometime after 4:15. I had phoned your office and understand you are out. Your
assistant suggested I send you an email.
Thank you,
Lesley
Assistant to Jeffrey Epstein
EFTA00649002
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From: IMI=I >
To:' *MINIII >
Subject: Alert - 8:30am De osition at Jack Goldberger's office 250 Australian Avenue, suite 1400 West PB
FL 33401
September 9, 2016 8:30 AM : 8:30am Deposition at Jack Goldberger's office 250 Australian Avenue, suite 1400
West PB FL 33401 ( )
EFTA00319542
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From: Darren Indyke <
To: Jeffrey Epstein
Subject: Re: Privileged and Confidential
Date: Thu, 08 Jan 2015 22:29:16 +0000
Rich gave me those dates, but Alfredo's deposition states that he worked for you though 2006. Is it possible that
Alfredo worked for you only 6 months?
DARREN K. INDYKE
DARREN K. INDYKE, PLLC
575 Lexington Avenue, 4th Floor
New York, New York 10022
Telephone:
Telecopier:
Mobile:
email:
****
The information contained in this communication is confidential, may be attorney-client
privileged, and is intended only for the use of the addressee. It is the property of
Darren K. Indyke, PLLC. 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, and destroy this
communication and all copies thereof, including all attachments.
Copyright of Darren K. Indyke, PLLC - ) 2014 Darren K.
Indyke, PLLC — All rights reserved.
****** ************************************************************************************
On Jan 8, 2015, at 5:27 PM, jeffrey E. < > wrote:
ill do it
On Thu, Jan 8, 2015 at 6:25 PM, Darren Indyke c wrote:
This is what I would respond to Alan.
"Alfredo Rodriguez was the houseman at 358 El Brillo Way in Palm Beach from September 1, 2004 through
and including February 10, 2005.
The papers have reported that Mr. Rodriquez passed away recently. I do not know if that is true."
Is there anything else you want me to tell Alan?
EFTA00673195
DARREN K. INDYKE
DARREN K. INDYKE, PLLC
575 Lexington Avenue, 4th Floor
New York, New York 10022
Telephone:
Telecopier:
Mobile:
email:
The information contained in this communication is confidential, may be attotney-client
privileged, and is intended only for the use of the addressee. It is the property of
Darren K. Indyke, PLLC. 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, and destroy this
communication and all copies thereof, including all attachments.
Copyright ofDarren K. Indyke, PLLC - C 2014 Darren K.
Indyke, PLLC — All rights reserved.
Begin forwarded message:
From: Alan Dershowitz
Subject: Re: 2015 0107 The Independent_Prince Andrew.pdf
Date: January 8, 2015 at 5:16:21 PM EST
To: "jeffrey E." <
Cc: Darren Indyke
According to Edwards Rodrigues does accuse me. Who is he. What years. Is he your enemy. If so why?
Sent from my iPhone
On Jan 8, 2015, at 5:11 PM, jeffrey E. > wrote:
darren can you give alan dates. ive told him that this is not his accuser
Forwarded message
From: Alan Dershowitz -IMMe
Date: Thu, Jan 8, 2015 at 6:08 PM
Subject: Re: 2015 0107 The Independent Prince Andrew.pdf
To: "jeffrey E." <1
Who is Rodrigues and when did he work for you ?
Sent from my iPhone
On Jan 8, 2015, at 5:01 PM, jeffrey E. > wrote:
EFTA00673196
this is not yours that is john alessi.
On Thu, Jan 8, 2015 at 5:58 PM, Alan Dershowitz wrote:
Are there two house men or this the same one ?
Sent from my iPhone
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
EFTA00673197
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA00673198
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1 pages
IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX 1.13
STATE OF FLORIDA
vs. NOTICE OF DEPOSITION
(Time change only pursuant to the request of Theodore S. Leopold, Esquire)
JEFFREY EPSTEIN,
Defendant.
:12 Ca
I aw*:t 4",1
•-
c2 gg
TO: Lanna Belohlavek, Esquire a we,-
rriz -n
Office of the State Attorney a. ca -r;
401 N. Dixie Hwy ea , Co F
ccr
West Palm Beach, Florida 33401 zoR -O
in
•
3).*-4n n,)
PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal IrttfaTclurgithat on
February 20. 2008 beginning at the hour of 2:00 P.M., at the Palm Beach CounRourethouse,
4' Floor. 205 North Dixie Highway. West Palm Beach, Florida 33401:
before Consor & Associates who is authorized by law to take depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
2:00 P.M.
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, Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite
200, Palm Beach Gardens, Florida 33410 and Jeffrey Herman, Esquire, 18205 Biscayne Boulevard,
Suite 2218, Miami, Florida, 33160 by via fax & mail this 8i6 day of February, 2008.
SIAM Of RORIOA • FALM &EACH I
ATTERBURY, GOLDBERGER, & WEISS, P.A.
I hereby certify that the
foregoing Is a true copy 250 Australian Avenue South, Suite 1400
of th ord I my office West Palm Beach, Florida 33401
CJ (561) 659-:300
(5.1)'. 5-86
A. GOLDBERGER, ESQUIRE
rida Bar No. 262013
MM15-STATE CASE-000199
EFTA 00049835
EFTA01250609
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From: Brad Edwards
Sent: Wednesday, December 19, 2018 12:55 PM
To:
Subject: Re:
I have to take a deposition early this morning. I can talk now if we still need to talk. I think everything is being handled
already for Sarah to sign.
Sent from my iPhone
On Dec 18, 2018, at 8:59 PM, J wrote:
I can talk in the morning.
Sent from my iPhone
On Dec 18, 2018, at 8:01PM, J , and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA_R1_01803831
EFTA02609746
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
TEE
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
2
EFTA_R1_01803832
EFTA02609747
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From: Jeffrey Epstein
To: Jean Luc Brunel
Subject: Re: C.L. v. Epstein - Notice of Deposition of in Miami
Date: Thu, 22 Apr 2010 10:09:11 +0000
Inline-Images: image.png
the lawyers on the girls side have now attempted to take the depp of M?
On Thu, Apr 22, 2010 at 4:53 AM, Jean Luc Brunel < > wrote:
Cannot open
On 4/21/10 5:15 PM, "Jeffrey Epstein" wrote:
Sent from my iPhone
Begin forwarded message:
From: "Connie Zaguirre, CP, FRP" <
Date: April 21, 2010 5:17:22 PM EDT
To: , "Darren Indyke"
Subject: C.L. v. Epstein - Notice of Deposition of
in Miami
Enclosed please find Plaintiff's Notice of Deposition of
on 5/18/10 in Miami.
Connie Zaguirre, CP, FRP - Assistant for Robert D. Critton, Jr.
303 Ban an Boulevard I Suite 400 I West Palm Beach I FL 33401
Phone: I Fax:
I umwocUmmcom
This e-mail contains legally privileged and confidential information
intended only for the individual or entity named within the message.
Should the intended recipient forward this message to another person or
party, that action could constitute a waiver of the attorney/client
privilege. If the reader of this message is not the intended recipient,
or the agent responsible to deliver it to the intended recipient, you
are hereby notified that any review, dissemination, distribution or
copying of this communication is prohibited. If this communications was
received in error, please notify us by reply e-mail and delete the
EFTA00779597
original message.
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No: 10-80447-cv-Marratlohnson
C. L.
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
DATE AND TIME: - LOCATION;
Min May 18, 2010
10:00 AM
Intelligent Office, 701 Britkell
Avenue. Suite 1550, Miami,
FL 33131
upon an oral examination before Videognpher and a Notary Public or officer authorized by law
to take depositions in the State ofFlorida. The oral examination will continue from day to day tmtil
completed. The depositions am bring taken for purposes of discovery, for use at trial or we being
taken for such other purposes as am permitted under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy o t Notice was mailed this
day of April 2010 to Jack A. Goldberger, Esq., 250 A • Suite 1400, We Palm
Beach, FL )3401; Bruce E. Reinhart, Esq., 250 Australian 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
EFTA00779598
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.
EFTA00779599
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To: Jeevacationfjeevacation©gmail.com]
From: Lesley Groff
Sent Fri 7/2/2010 3:14:09 PM
Subject: RE: Bennet Moskowitz
Fyi- Steve Rinehart will be in a deposition today and not available to be on the call anyway!
From: Jeevacation imailtoleevacation©gmail.com]
Sent: Friday, July 02, 2010 10:00 AM
To: Lesley Groff
Subject: Re: Bennet Moskowitz
1230 office
Sent from my iPhone
On Jul 2, 2010, at 9:44 AM, "Lesley Groff' te:
Bennet Moskowitz would like to set up a call with you today. What time is good
for you and did you want anyone else (Steve Rinehart?) on the call as well?
Les
EFTA_R1_01471749
EFTA02410752
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462
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and PAUL G.
CASSELL,
Plaintiffs,
vs.
ALAN M. DERSHOWITZ,
Defendant.
VIDEOTAPE CONTINUED DEPOSITION OF
ALAN M. DERSHOWITZ
VOLUME 4
Pages 462 through 647
Tuesday, January 12, 2016
1:05 p.m. - 4:45 p.m.
Stenographically Reported By:
Kimberly Fontalvo, RPR, CLR
Realtime Systems Administrator
www.phi sre orting.com
EFTA00615583
463
1 APPEARANCES:
2
On behalf of Plaintiffs:
3
SEARCY, DENNEY, SCAROLA
4 BARNHART & SHIPLEY, P.A.
5
6
7
8 On behalf of Defendant:
9 COLE, SCOTT & KISSANE, P.A.
Dadeland Centre II - Suite 1400
10
11
12 :
I I I. P , . (Via phone)
IRIR
13 il
--an --
14 SWEDER & ROSS, LLP
15
BY: KENNETH A. SWEDER, ESQ.
16
17 --and--
18 WILEY, REIN
19
BY: RICHARD A. SIMPSON, ESQ.
20
21
22
23
24
25
www.piiiiiiiiiiiiir.com
EFTA00615584
464
1 APPEARANCES (Continued):
2
3 On behalf of Jeffrey Epstein:
4
5 Sligi
BY: DARREN K. INDYKE, ESQ. (Via phone)
6
7 On behalf of
8 BOIES, SCHILLER & FLEXNER, LLP
9
BY: SIGRID STONE MCCAWLEY, ESQ.
10
11
12 ALSO PRESENT:
13 Edward J. Pozzuoli, Special Master
14 Sean D. Reyes, Utah Attorney General Office
15 Travis Gallagher, Videographer
16
17
18
19
20
21
22
23
24
25
www.phi sre orting.com
EFTA00615585
465
1 INDEX
2
3
Examination Page
4
5 VOLUME 4 (Pages 462 - 647)
6
7 Certificate of Oath 645
Certificate of Reporter 646
8 Read and Sign Letter to Witness 647
Errata Sheet (forwarded upon execution) 648
9
10 PLAINTIFF EXHIBITS
11
12 No. Page
13 19 Proposed Joint Letter to the Special 501
Master
14
20 Document reflecting entry for Bands, 548
15 Doug
16 21 562
17
18 22 Letter dated Jul 6 2007 from Gerald 612
B. Lefcourt to First
19 Assistant U.S. torney an o hers
22 pages
20
23 Document titled NewsRoom/Alan 623
21 Dershowitz to talk in Alburquerque
22 24 628
23
24
25
www.phi sre orting.com
EFTA00615586
466
1 VIDEOGRAPHER: Going back on the record.
2 The time is approximately 1:05 p.m.
3 MR. INDYKE: This is Darren Indyke. If it
4 would be okay with everyone, I would like to
5 clarify a couple of points for the record.
6 SPECIAL MASTER POZZUOLI: Go ahead.
7 MR. INDYKE: First, I apologize for the
8 spotty reception during the morning session. I
9 was having difficulty hearing you folks, and I
10 think you were having some difficulty hearing
11 me. I think I've corrected it, but if I could
12 ask if you could move the mic closer to him
13 somehow or if I let you know that I can't hear,
14 if somebody could just speak up.
15 MR. SCAROLA: Did we turn that speaker
16 volume up?
17 MR. SIMPSON: Let's turn up the volume.
18 MR. INDYKE: Secondly, as to the argument
19 that work product belongs to the attorney and
20 not the client, I want to make sure that it's
21 clear that we disagree with that vehemently.
22 We believe that it is a client's every bit
23 as much as an attorney's and an attorney has no
24 right to waive that privilege over the
25 objection of a client. If that were true,
www.phi sre orting.com
EFTA00615587
467
1 there would be nothing improper with an
2 attorney publishing his entire case file over
3 the objection of his client with the exception
4 of communications back and forth between
5 attorney and client. Strategies, witnesses,
6 things like that could be disclosed over the
7 objection of a client, and that's just not the
8 case.
9 So for the record, Mr. Epstein reasserts
10 the work product privilege and would continue
11 do so. And I would instruct Mr. Dershowitz not
12 provide any response to any question that would
13 require Mr. Dershowitz to invade that
14 privilege.
15 Third, I guess as to the joint defense
16 agreement, it is our position that any party to
17 the joint defense agreement may assert it, and
18 it doesn't require disclosure of all parties to
19 the agreement in order for the assertion to be
20 valid.
21 I would note that disclosure of the
22 parties to a joint defense agreement are often,
23 by the terms of a joint defense agreement,
24 subject to confidentiality and, thus, protected
25 by the privilege.
www.phi sre orting.com
EFTA00615588
468
1 And I would also point out that it's not
2 necessary for a person to be a party to a joint
3 defense agreement for the communications with
4 that person by a lawyer who is making those
5 communications on behalf of the client party to
6 the agreement to be subject to the joint
7 defense agreement.
8 And while we need to do some more
9 background research to get the full details of
10 the joint defense agreement, I would -- for
11 those reasons, to the extent that any
12 disclosure in response to any questions posed
13 to Mr. Dershowitz would require Mr. Dershowitz
14 to invade that joint defense agreement, we
15 would instruct -- we would object and instruct
16 that Mr. Dershowitz not respond. I think that
17 covers everything that I have.
18 SPECIAL MASTER POZZUOLI: Thank you.
19 Let's proceed.
20 MR. SCAROLA: Before we proceed, I want to
21 note for the record that the various
22 transcripts of statements made by
23 Mr. Dershowitz that had been requested during
24 the earlier session of the deposition were
25 marked as Exhibit Number 1 to the prior
www.phi sre orting.com
EFTA00615589
469
1 sessions of Mr. Dershowitz's deposition.
2 I believe that everything that was
3 referenced has been disclosed. To the extent
4 that opposing counsel identifies anything that
5 is not included in Composite Exhibit Number 1
6 previously marked, we would be happy to provide
7 a copy of that as soon as a copy --
8 MR. INDYKE: Is that Mr. Scarola?
9 MR. SCAROLA: It is, yes.
10 SPECIAL MASTER POZZUOLI: Hang on. Speak
11 up a little bit, Jack.
12 MR. SCAROLA: Certainly. As soon as a
13 copy that does not include work product
14 notations is available, and the portions of
15 statements made by Mr. Dershowitz not included
16 in Exhibit Number 1 are identified to us, we
17 will provide those.
18 MR. SCOTT: I think what we most want,
19 Jack, are the -- I think we have one
20 transcript, but I think there's another
21 transcript of the bench and Bar that we need.
22 MR. SCAROLA: There are multiple
23 transcripts included in Exhibit Number 1.
24 MR. EDWARDS: If there are transcripts
25 that you need that are not included in Exhibit
www.phi sre orting.com
EFTA00615590
470
1 Number 1, tell me. I'll get them to you, and
2 I'll get them to you tomorrow since we're here
3 again.
4 MR. SCAROLA: I just want the record to
5 reflect that I believe that everything that
6 we've made reference to is included in Exhibit
7 Number 1. If I'm incorrect in that regard, you
8 let us know what it is, we'll give it to you.
9 SPECIAL MASTER POZZUOLI: Darren, anything
10 on your end? You okay?
11 MR. INDYKE: Yep.
12 SPECIAL MASTER POZZUOLI: I would welcome
13 the parties just to get together to make sure
14 they have a complete set of what they need, and
15 we'll go from there.
16 MR. EDWARDS: Absolutely. Just for the
17 record, my only real objection was not turning
18 over what I had marked and my work product.
19 SPECIAL MASTER POZZUOLI: I understood.
20 MR. EDWARDS: I'll get everything to him
21 tomorrow.
22 SPECIAL MASTER POZZUOLI: I took it that
23 way.
24 BY MR. EDWARDS:
25 Q. Going back to testing the credibility of
www.phi sre orting.com
EFTA00615591
EFTA00615592
472
1 A. I imagine there would be if there were
2 videotapes. I've always said from the beginning, I
3 hope there are videotapes of every moment in
4 life, because they would exculpate
5 me completely. So I hope there are videotapes.
6 Q. Aren't you aware that there were
7 videotapes that were taken within your client
8 Jeffrey Epstein's various homes?
9 MR. INDYKE: Objection. Work product,
10 attorney-client. Common interest.
11 SPECIAL MASTER POZZUOLI: Carve out the
12 privileged issue and non-privileged, if he
13 gained information through a nonprivileged
14 source.
15 BY MR. EDWARDS:
16 Q. Well, the statement was -- which I was not
17 going there. The statement was, if there are
18 videos, I want them all out there?
19 A. Absolutely.
20 Q. So, isn't it true that you know that there
21 were indeed videos taken from within your client's
22 various homes?
23 MR. INDYKE: Same objection.
24 BY MR. EDWARDS:
25 Q. Privileged or nonprivileged.
www.phi sre orting.com
EFTA00615593
473
1 MR. SCOTT: Asked and answered in the last
2 depo.
3 A. I hope there were videos. I hope there
4 are videos of every moment of ' life
5 from the time she allegedly met Jeffrey Epstein to
6 the time she left. I hope there were videos in
7 every bedroom. I hope there were videos in every
8 massage room. I hope there are videos all over.
9 And from day one, I categorically stated
10 that there could be no photograph, no video that
11 would demonstrate that what she said was true,
12 because I knew it was false. She knew it was false.
13 And you knew it was false.
14 BY MR. EDWARDS:
15 Q. In representing a client, don't you try to
16 determine or ascertain what evidence does exist that
17 may incriminate or exonerate any particular client?
18 A. Of course.
19 Q. Okay. In making that inquiry in this
20 case, haven't you learned that there are --
21 SPECIAL MASTER POZZUOLI: Which case?
22 BY MR. EDWARDS:
23 Q. In the case in which you represented
24 Jeffrey Epstein, haven't you learned that there were
25 video recordings taken from within Jeffrey Epstein's
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1 various homes as well as his airplane?
2 MR. INDYKE: Objection, same objection.
3 Instruct him not to answer.
4 A. I hope there were.
5 BY MR. EDWARDS:
6 Q. Will you then assist us
7 A. Yes.
8 Q. -- in obtaining those videos from your
9 client?
10 A. I will assist you in getting any possible
11 videotapes of r any of the
12 locations where the false accusation against me was
13 made. I would be thrilled to have videos of every
14 moment of my life during that period of time, and
15 every moment of her life. Because they would prove
16 conclusively that which I know to be conclusively
17 false, namely that she made up the stories about me.
18 Q. Okay. Just so I understand your
19 agreement, is that --
20 MR. INDYKE: Just so we're clear,
21 Mr. Epstein is not waiving any of his
22 objections as to any such information to the
23 extent that it exists.
24 BY MR. EDWARDS:
25 Q. Okay. Well, this video or photograph --
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1 if there are videos or photographs of
that have been taken or recorded from
3 Jeffrey Epstein's home, is that -- is that evidence
4 that you will assist us in obtaining?
5 A. I will try my best to try to get every
6 possible
7 MR. INDYKE: Objection.
8 A. -- photograph -- I'm entitled to say what
9 I'll try to best to do. I will try my best to get
10 every possible video, photograph, and any other
11 piece of objective evidence because I know it will
12 all completely prove beyond any doubt that I wasn't
13 there.
14 BY MR. EDWARDS:
15 Q. And if that information has already
16 exchanged hands -- that evidence has already
17 exchanged hands from Jeffrey Epstein's hands to the
18 hands of his attorneys, as part of their work
19 product, would you agree to waive your work product
20 privilege to produce that evidence?
21 MR. SCOTT: Objection.
22 MR. INDYKE: Objection.
23 A. I don't have any such evidence. I wish I
24 did.
25
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1 BY MR. EDWARDS:
2 Q. With respect to the search warrant that
3 was executed on Jeffrey Epstein's house, isn't it
4 true that just before that search warrant was
5 executed, the -- Jeffrey Epstein's legal team
6 ordered that three computers be removed from Jeffrey
7 Epstein's home that contained pornographic images,
8 including those of
9 A. I made no such order.
10 MR. INDYKE: Same objection. And instruct
11 not to answer.
12 BY MR. EDWARDS:
13 Q. I didn't ask if you made the order. Isn't
14 it true that that occurred?
15 MR. INDYKE: Same objection.
16 MR. SIMPSON: Darren?
17 SPECIAL MASTER POZZUOLI: I'm not so sure
18 you can waive that objection.
19 A. I wish I could.
20 BY MR. EDWARDS:
21 Q. Didn't the U.S. Attorney's Office issue
22 grand jury subpoenas to the investigators that were
23 working on Jeffrey Epstein's behalf and were holding
24 those computers, and those grand jury subpoenas
25 outstanding at the time that the case resolved?
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1 A. All I can say --
2 MR. INDYKE: Same objection and
3 instruction.
4 A. -- is I wish every video, every computer,
5 I wish everything that would show where
was had been turned over and would be turned
7 over.
8 MR. SCAROLA: Mr. Dershowitz's repeated
9 comments about what he wishes would happen are
10 an indirect statement that if he could answer
11 the questions, the responses that he would give
12 would be favorable to him and would exonerate
13 him.
14 His wishes are not the subject of the
15 inquiry. And every occasion on which he
16 expresses a wish and refuses to give an answer
17 is unresponsive to the questions that are being
18 asked, and should be stricken.
19 They also constitute a waiver to the
20 extent that they imply that if the question
21 could be answered, the answer would be
22 favorable.
23 I would ask you to instruct
24 MR. INDYKE: And to the extent that they
25 imply a waiver --
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1 SPECIAL MASTER POZZUOLI: Hang on a
2 second. Let him finish.
3 MR. INDYKE: I apologize, Mr. Scarola
4 MR. SCAROLA: That's quite all right,
5 thank you.
6 I know that over the speakerphone, it's
7 difficult, and I take no offense to the
8 interruption. I know it was inadvertent.
9 But I would ask that the witness be
10 instructed to discontinue that improper
11 assertion of statements of opinion when no
12 opinions are being requested.
13 SPECIAL MASTER POZZUOLI: Counsel, do you
14 have a response? I think Mr. Scarola is done.
15 MR. INDYKE: My response is to the extent
16 that you're attempting to imply anything
17 from -- imply a waiver from Mr. Dershowitz,
18 Mr. Epstein does not waive, and instructs
19 Mr. Dershowitz that he can make no such waiver.
20 THE WITNESS: I have not refused to
21 answer.
22 SPECIAL MASTER POZZUOLI: Hang on one
23 second. Let me say this: I would suggest that
24 I don't take such inference that he's waiving
25 based upon his general statements.
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1 What -- we have been down a little bit of
2 this road this morning on trying to get to what
3 appears to be privileged information or
4 information that -- or activity that was
5 undertaken or not undertaken during the course
6 of the representation, the relationship the
7 attorney-client relationship between
8 Mr. Dershowitz and Mr. Epstein.
9 And at this point, based upon the
10 objection, I will uphold the objection and
11 we'll move forward.
12 MR. SCAROLA: The second part of my
13 request is that Mr. Dershowitz be instructed to
14 refrain from expressing a desire to answer
15 questions. It's not responsive. It implies
16 that if he could answer, the answers would be
17 favorable.
18 The implication is improper, and the
19 insertion into the record of the implication is
20 improper. If he can't answer the question, he
21 should simply say he cannot answer based on
22 privilege.
23 THE WITNESS: Can I respond?
24 SPECIAL MASTER POZZUOLI: No. Let me
25 respond.
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1 I think that's appropriate. I do actually
2 agree with Mr. Scarola in this respect. I do
3 think that you should be responsive
4 specifically to the question if you can.
5 Where you can't, you state you can't. I
6 believe that the record is now full of your
7 views on some of this in a generic way, and so
8 with that said, I would ask that you be more
9 pointed with your answers.
10 THE WITNESS: I appreciate that. I just
11 want to comment that I did not ever refuse to
12 answer any of those questions. It was
13 instructed not to answer any of those
14 questions.
15 SPECIAL MASTER POZZUOLI: I do understand
16 that. For purposes of some efficiency here, I
17 would like to get through this within the time
18 alloted.
19 MR. EDWARDS: Me, too. Thank you.
20 BY MR. EDWARDS:
21 Q. Is there any nonprivileged information
22 which would demonstrate whether
23 statement that she was flown on Jeffrey Epstein's
24 plane while underage was true or false?
25 A. I'm sure there must be, but I don't have
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1 it in my mind right now, so I can't answer that
2 question.
3 Q. The flight logs were previously marked
4 as --
5 MR. SCAROLA: Exhibit 7.
6 BY MR. EDWARDS:
7 Q. -- as Exhibit 7 to the deposition. I'll
8 show you pages from Exhibit 7 which indicate the
9 dates of the flight logs for those on the phone
10 November 2002 through January -- sorry,
11 November 2000 through January 2001 and January 2001
12 through February 20th, 2001.
13 SPECIAL MASTER POZZUOLI: Counsel?
14 MR. SCOTT: Okay.
15 A. Yes, I see the flights that you have
16 marked in green.
17 BY MR. EDWARDS:
18 Q. Do the flight logs indicate
passenger on Jeffrey Epstein's plane
II~sa
20 with Jeffrey Epstein?
21 A. Well, the first one I look at does not.
22 It has and Although it's
23 underlined, it doesn't suggest
24 The second one does say
■ . And the fourth and fifth ones say
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1 . And on the next page, two of them say
2 , yes.
3 Q. These in the year 2000 and early 2001; is
4 that correct?
5 A. I can't see dates. I see 2001. I see
6 November 2000. Could you remind me of
' birthday.
8 Q.
9 A. So she would be I at this
10 time.
11 Q. So she's traveling as a passenger under
12 the age of 18? That's my question.
13 A. Under the age of 18, but the age of
14 consent in numerous places that she flew to were 17
15 and 16. So New York, the age is 17, to my
16 recollection. And in New Mexico, I think it's 17.
17 And the Virgin Islands, I think it's 16. So the
18 answer to the question is she underage might well be
19 no.
20 Q. My question was, is there nonprivileged
21 information that would indicate the truth or falsity
22 of her statement that she traveled on Jeffrey
23 Epstein's airplane with Jeffrey Epstein while under
24 the age of 18?
25 A. I do not know of any statement that she
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1 said -- may have said it, but I don't have in my
2 mind any statement that says below the age of 18 as
3 distinguished from when she was underage. So you
4 would have to show me. If the statement was below
5 the age of 18, that would be correct. If the
6 statement would be underage, that would be more
7 questionable.
8 Q. Do you know the purpose for which she was
9 traveling with Jeffrey Epstein during the flights
10 indicated on those logs?
11 A. I do not.
12 MR. SCOTT: Privileged.
13 MR. INDYKE: Objection, work product,
14 attorney-client, common interest.
15 BY MR. EDWARDS:
16 Q. Your answer is "I do not"?
17 A. I do not.
18 Q. You have not ascertained from any source,
19 is what you're telling us, the purpose for her
20 travels with Jeffrey Epstein, correct?
21 MR. INDYKE: Objection. Same objection
22 and instruction.
23 BY MR. EDWARDS:
24 Q. You are unable to answer, or you have not?
25 A. I have been instructed not to answer.
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1 Q. I misunderstood you. I thought you said
2 earlier "I have not," indicating that you don't know
3 the purpose?
4 A. I said that in answer to one question.
5 You've asked me other questions.
6 Q. Is there a legitimate purpose for her
7 being 17 years old, traveling with Jeffrey Epstein?
8 MR. SCOTT: Objection, argumentative.
9 MR. INDYKE: Objection. Same objection,
10 same instructions.
11 BY MR. EDWARDS:
12 Q. Isn't it a federal crime to knowingly
13 transport an individual who has not attained the age
14 of 18 years in interstate commerce with the intent
15 that that individual engage in prostitution or in
16 any sexual activity?
17 A. I haven't read the statute clearly, but I
18 think that's an accurate paraphrase of my
19 understanding of the law, yeah.
20 Q. Would you agree that that flight log in
21 front of you indicates a federal crime was being
22 committed against at the time when
23 she has said a federal crime was being committed
24 against her?
25 A. Oh, absolutely not.
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1 MR. INDYKE: Objection.
2 A. Does not prove a federal crime.
3 MR. INDYKE: Same objection, same
4 instruction.
5 BY MR. EDWARDS:
6 Q. So that goes back to my last question.
7 What is, then, the legitimate reason that causes
8 that flight to fall outside of this criminal statute
9 that I just read to you?
10 MR. INDYKE: Same objection, same
11 instruction.
12 A. I can give this answer. My understanding
13 of federal law imposes the burden of proof on the
14 prosecution to demonstrate one of the illicit
15 purposes, and this does not satisfy that burden of
16 proof. So this would not prove that a federal crime
17 occurred. It would prove one element of that crime.
18 BY MR. EDWARDS:
19
20
21
22
23
24
25
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1 BY MR. EDWARDS:
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21 SPECIAL MASTER POZZUOLI: Move forward.
22 BY MR. EDWARDS:
23 Q. Let me try to understand that which you
24 are explaining right now, which is are you saying
25 that if she was traveling on Jeffrey Epstein's
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1 airplane while underage for the purposes of sex and
2 or prostitution, that --
3 MR. INDYKE: Same objection, same
4 instructions.
5 BY MR. EDWARDS:
6 Q. -- she was not being sexually trafficked
7 or would not be a victim of that statute?
8 MR. INDYKE: Same objection, same
9 instruction.
10 MR. EDWARDS: I'm asking a hypothetical
11 now based on his last statement.
12 MR. SCOTT: That's not a hypothetical.
13 SPECIAL MASTER POZZUOLI: That's not how
14 you framed it.
15 BY MR. EDWARDS:
16 Q. Let me reframe it, then.
17 Assuming that -- I'll give you a
18 hypothetical based on what you say her friends have
19 told you, which is that she is free to leave while
20 being taken across state lines by Jeffrey Epstein.
21 This is the hypothetical. And being used for sexual
22 purposes. Is she, in that hypothetical, not a
23 victim to sexual trafficking?
24 MR. SCOTT: Objection to form,
25 speculation, argumentative. Can you answer
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1 that?
2 A. I can answer it. Since you gave me a
3 hypothetical, as a law professor for 50 years, I
4 would give this as a hypothetical to my class. I
5 would ask my students do you think it's trafficking,
6 do you think a woman has been trafficked when she
7 voluntarily, below the age of consent in some
8 states, above the age of consent in other states,
9 when she voluntarily engages in sexual conduct for
10 money, free to leave at any time.
11 I think it would be an interesting
12 classroom discussion about whether that constitutes
13 trafficking.
14 That's a different question from whether
15 or not that would violate the statute. That would
16 violate the statute. But your question is, would it
17 constitute trafficking. That would be a very
18 interesting law school hypothetical.
19 BY MR. EDWARDS:
20 Q. In your opinion, does it constitute
21 trafficking?
22 A. I think the word "trafficking" is
23 overused, and I think should be reserved for the
24 kinds of people who I have enormous sympathy for,
25 people who have no choice, no options, whose
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1 passports have been taken away, who have been forced
2 and coerced in some way to engage in sexual conduct.
3 And I think it begins to weaken the very
4 important term "trafficking" when it's applied to a
5 volunteer, close to her 18th birthday who was
6 enjoying and spending money and has the option of
7 leaving. I know that Sigrid McCawley is shaking her
8 head, but that's my honest opinion.
9 Q. Does your answer to the hypothetical
10 change if we rewind time
11 when she's 15 or
12 16 years old? Meaning are you making a distinction
13 because she's 17 as opposed to 16 or 15? If so,
14 what's the cutoff?
15 A. Well, I think that age is relevant
16 MR. INDYKE: For my clarification, this is
17 all hypothetical?
18 MR. SCAROLA: Yes, it is.
19 A. Age is one of the relevant factors. It's
20 not the only relevant factor. It's one of the
21 relevant factors. That's why your hypothetical was
22 17, almost 18, 17 and a half.
23 BY MR. EDWARDS:
24 Q. Let's get that right. That's when,
25
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1 A. We're talking about
2 SPECIAL MASTER POZZUOLI: We're still
3 operating under the hypothetical?
4 MR. EDWARDS: We are. I thought he said
5 that my hypothetical was almost 18. Which in
6 this hypothetical, she turns
7
8 THE WITNESS: =, the same year.
9 BY MR. EDWARDS:
10 Q. Was she lying when she said that
11 Epstein --
12 SPECIAL MASTER POZZUOLI: Are we now done
13 with the hypothetical?
14 MR. EDWARDS: Yes, we are.
15 BY MR. EDWARDS:
16 Q. engaged in sex with many underage
17 girls? Was she lying when she said that?
18 MR. INDYKE: Same objection, same
19 instructions.
20 A. I can only say this. You --
21 MR. SIMPSON: Was there an instruction?
22 A. There was an instruction, but I can answer
23 without that.
24 You have accused me of having sex with
25 many underage girls --
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1 MR. EDWARDS: I move to strike this as
2 nonresponsive to my question.
3 A. -- based on no evidence whatsoever.
4 MR. EDWARDS: I want a ruling on the
5 Motion to Strike.
6 SPECIAL MASTER POZZUOLI: Let me hear the
7 rest of it.
8 A. So when you say "many," I need to know
9 with some precision what you have in mind.
10 SPECIAL MASTER POZZUOLI: I'll strike the
11 first part of it, the first part of his answer.
12 And if you can assist him in defining " many."
13 BY MR. EDWARDS:
14 Q. Sure. You do know Bob Josefsberg,
15 correct?
16 A. I've known him since 1959.
17 Q. And you are aware that he represented, I
18 believe, more than 15 girls who claimed to have been
19 victims of Mr. Epstein in this case, aren't you?
20 A. I recommended him for that job because I
21 think so highly of him.
22 Q. And in his Complaints, are you aware that
23 he's made the allegation that Defendant Epstein has
24 a sexual preference for underage minor girls? Are
25 you aware of that?
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1 MR. SCOTT: Just for the record, object to
2 the relevancy of all of this.
3 A. I'm not aware of that.
4 MR. INDYKE: Just for the record, to the
5 extent that Alan's answer requires him to
6 invade privilege, I would object and instruct
7 him not to answer.
8 SPECIAL MASTER POZZUOLI: Within the
9 confines of the privilege objection, if you can
10 answer.
11 A. I'm not aware that he said that. I
12 haven't read his pleadings.
13 BY MR. EDWARDS:
14 Q. Okay. Are you aware that in his
15 pleadings, he wrote "Defendant Epstein used his
16 resources and his influence over vulnerable minor
17 girls to engage in a systemic -- systematic pattern
18 of sexually exploited behavior"?
19 A. I'm not aware.
20 MR. INDYKE: Same objection, same
21 instruction.
22 A. I was not involved in that aspect of the
23 case.
24 BY MR. EDWARDS:
25 Q. You were not involved in the facts part of
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1 the case?
2 A. I was not involved in the compensation
3 part of the case. The part that Bob Josefsberg was
4 involved in, I was not involved in.
5 MR. INDYKE: Alan, just admonishment,
6 let's not go into the subject matter of your
7 representation, please.
8 BY MR. EDWARDS:
9
10
11
12
13
14
15
16
17
18 BY MR. EDWARDS:
19
20
22
23
24
25
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1 question.
2 BY MR. EDWARDS:
3 Q. In 2009, when that Complaint and that
4 allegation was asserted, are you aware that Jeffrey
5 Epstein never refuted that allegation in any
6 pleading?
7 MR. INDYKE: Same objection, same
8 instruction.
9 BY MR. EDWARDS:
10 Q. Were you representing Jeffrey Epstein in
11 2009?
12 A. Not in connection with that case. And I
13 was not aware of what his response was, if any.
14 Q. Are you aware that after that allegation
15 was made by , that Jeffrey Epstein
16 paid money to settle her case?
17 MR. INDYKE: Same objection, same
18 instruction.
19 MR. SCOTT: Let me object to all the
20 relevancy of this.
21 A. My understanding is that the plea bargain
22 required him to make payments regardless of what his
23 views may have been, that he was absolutely required
24 to make those payments. He had no discretion.
25 That's my understanding. I may be wrong, but you
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1 can check the actual nonprosecution agreement, but
2 that's my understanding of what it said, that he
3 could not contest anything.
4 BY MR. EDWARDS:
5 Q. You were one of the attorneys that
6 represented Jeffrey Epstein in the negotiations with
7 the United States Attorney's Office, right?
8 A. Right, along with Kenneth Starr --
9 MR. INDYKE: Same objection. Objection.
10 A. No, I don't think you can object to that.
11 These are people who are at the hearings, at the
12 events with the U.S. Attorney. The people who were
13 at the events representing Jeffrey Epstein is not
14 privileged, included Roy Black, Ken Starr, Marty
15 Weinberg, Jay Lefkowitz --
16 MR. SCAROLA: Not responsive.
17 A. -- Jerry Lefcourt.
18 BY MR. EDWARDS:
19 Q. I only asked if you were one of the
20 lawyers.
21 A. I was one of them, yes.
22 Q. The answer is yes?
23 A. The complete answer is yes, but the rest
24 of the people were part of the legal team.
25 Q. I will ask you when I want somebody else's
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1 name.
2 Were you a part of the negotiations in
3 October of 2007 when the special matter was
4 selected? You remember that part?
5 A. Is the special master Josephsburg?
6 MR. INDYKE: Same objection, same
7 instruction.
8 BY MR. EDWARDS:
9 Q. Yes.
10 A. My recollection is that I was simply asked
11 for a recommendation, but I played no further role.
12 Q. Were you aware that there was a joint
13 letter to the special master created between Jeffrey
14 Epstein's attorneys and the United States Attorney's
15 Office describing the investigation?
16 MR. INDYKE: Same objection, same
17 instruction.
18 A. I'm not -- as I sit here today, I have no
19 recollection of that.
20 BY MR. EDWARDS:
21 Q. Was lying when she says
22 that while underage, she was made to massage Jeffrey
23 Epstein in the nude, while he masturbated?
24 A. I have no idea.
25 MR. INDYKE: Same objection, same
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1 instruction.
2 BY MR. EDWARDS:
3 Q. If I show you the proposed joint letter to
4 the special master, will it refresh your
5 recollection?
6 A. I want to add to the last question When
7 I say I have no idea,
8
9
10
11 MR. EDWARDS: Move to strike as
12 nonresponsive.
13 A. But that's relevant to standing naked and
14 being masturbated.
15 SPECIAL MASTER POZZUOLI: Move on to your
16 next question.
17 A. Yes.
18 BY MR. EDWARDS:
19 Q. When I am asking for nonprivileged
20 information or evidence that would give you the
21 ability to tell me whether is lying
22 when she says she had sex with Jeffrey Epstein while
23 underage, would you consider a joint letter crafted
24 between Jeffrey Epstein's lawyers and the United
25 States Attorney's Office to form the basis of that
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1 answer? Let me rephrase the question.
2 When I'm asking for nonprivileged
3 information that you may have to demonstrate the
4 truth or falsity of ' statement that
5 she was made to have sex with Jeffrey Epstein while
6 underage, would you consider the joint letter to the
7 special master evidence from which you could draw an
8 answer?
9 MR. SCOTT: Objection.
10 A. I would have to know more about it than
11 that. I would have to know the nature of the
12 letter, the reason it was sent.
13 BY MR. EDWARDS:
14 Q. Would you like to review the letter? Is
15 that going to help you?
16 SPECIAL MASTER POZZUOLI: Ask him if he's
17 seen the letter first.
18 BY MR. EDWARDS:
19 Q. You were part of the team that was mainly
20 negotiating with U.S. Attorney's Office, correct?
21 A. I was only negotiating the criminal part
22 of the case.
23 Q. Okay. I'm going to show you the letter,
24 and if you had nothing to do with it, tell me that.
25 If you've never seen it before, then tell me that.
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1 I guess my first question is, have you
2 seen it?
3 MR. INDYKE: I would object to that.
4 MR. SCOTT: I would like to make a request
5 for this depo and future depositions, if they
6 are going to show exhibits to a witness, I
7 think we should be -- have a copy of them.
8 We provided copies to you of all exhibits
9 we used during the deposition of your client.
10 And I think if you're going to pull out
11 exhibits and have one, you should have at least
12 copies for counsel, and I would agree to do the
13 same thing, rather than having to run and make
14 a copy and all the rest of it.
15 MR. EDWARDS: I wasn't ready for him to be
16 unfamiliar with his and his legal team's
17 correspondence.
18 MR. SCOTT: I understand, but you haven't
19 had any all day. So all I'm asking you,
20 Mr. Edwards, is that we have copies of exhibits
21 that you intend to confront the witness with.
22 That's -- as you pointed out, you've got all
23 the questions laid out, so you know where we're
24 headed. There's a note on here. Do you want
25 that on there?
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1 MR. EDWARDS: No.
2 MR. SCOTT: It's one of your cheat sheet
3 notes. I don't know if you really want that on
4 there.
5 MR. EDWARDS: It just says "Isn't this
6 nonprivileged?"
7 MR. SCOTT: Okay. It's still an exhibit
8 going into evidence, right? Without your
9 notes?
10 MR. SIMPSON: Can we get it marked?
11 THE WITNESS: This is a draft, not a
12 letter.
13 MR. EDWARDS: I said it's a proposed
14 letter. I read the title exactly.
15 (Thereupon, marked as Plaintiff Exhibit
16 19.)
17 A. This is not -- it's not familiar to me
18 except that what I said previously that as part of
19 the resolution of this case, Mr. Epstein agreed he
20 would not contest jurisdiction for the victims who
21 chose to sue him, et cetera, is consistent with my
22 memory, but I have no recollection of actually
23 seeing this draft, this proposed draft.
24 MR. SCOTT: That's number?
25 COURT REPORTER: Nineteen.
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1 BY MR. EDWARDS:
2 Q. Wouldn't you agree wasn't
one of the listed victims to the
4 nonprosecution agreement?
5 A. If so, I was not aware of.
6 MR. INDYKE: Same objection, same
7 instruction.
8 BY MR. EDWARDS:
9 Q. As you sit here today, after having made
10 many statements about being a
11 serial liar --
12 A. She is.
13 Q. -- you have no idea whether she was a
14 listed victim to the nonprosecution agreement?
15 MR. SCOTT: Objection, asked and answered.
16 MR. INDYKE: Same objection, same
17 instruction.
18 A. Right now, I have no recollection of
19 whether she was listed or not.
20 BY MR. EDWARDS:
21 Q. Okay.
22 A. I know that the FBI tried to speak to her
23 and she wouldn't speak to them is my recollection.
24 MR. SCAROLA: That's not responsive.
25 MR. EDWARDS: Not responsive.
www.phi sre orting.com
EFTA00615622
502
1 MR. SCAROLA: Move to strike.
2 SPECIAL MASTER POZZUOLI: That, I will
3 strike. Move forward.
4 BY MR. EDWARDS:
5 Q. Was lying when she says that
6 Jeffrey Epstein also had sex with a girl named
8
9 MR. INDYKE: Same objections, same
10 instruction.
11 MR. SCOTT: Can you answer that?
12 A. I've never heard that name. It's not
13 familiar to me at all.
14 BY MR. EDWARDS:
15 Q. Was lying when she says
16 she traveled to Jeffrey Epstein's island when
17 underage?
18
DataSet-10
Unknown
1 pages
From: " ana
To: MMIEN(NY) (FBI)" .M.IMM>, l'a (NYPD)"
Cc: 'naira11.. ).
H
Subject: Trial subpoena for deposition court reporter
Date: Sun, 29 Aug 2021 00:11:35 +0000
Attachments: 2021.08.28_Court_Subpoena_-afa_Vol.pdf
H
Would you please serve the attached subpoena on ? She was the court reporter for
deposition, and we may need to call her to admit prior statements about "MI" calling her about
work. I've attached a copy of the deposition transcript for reference, which should hopefully help in tracking
Sandra down.
if you wouldn't mind, I'd be grateful if you would please add Sandra to your list of custodians to shepherd
through trial.
Thanks all,
Assistant United States Attorney
Southern District ofNew York
1 St. Plaza
New York, NY 10007
EFTA00099098
DataSet-10
Unknown
73 pages
Kretschmar, Dean - Vol. ROUGH
February 11, 2011
Page 1
1 ROUGH DRAFT
2 DEPOSITION Of DEAN KRETSCHMAR
3 FEBRUARY 11, 2011
4
5 DIRECT EXAMINATION
6 BY MRS. APRIL:
7 Q. Sir, would you say your full name.
8 A. Dean Russell Kretschmar. Last name is
9 K-r-e-t-s-c-h-m-a-r.
10 Q. Where do you live?
11 A. I live here in Fort Lauderdale.
12 Q. And what's your address; business or home, either?
13 MRS. STREETER: Can we do this off the record?
14 MRS. APRIL: Sure.
15 MRS. STREETER: Go ahead.
16 (WHEREUPON, the answer was provided
17 off-the-record).
18 BY MRS. APRIL:
19 Q. Did you receive a subpoena to be here today, do you
20 know if you did?
21 A. Yes, I did.
22 Q. And are you represented by counsel today?
23 A. Yes
24 Q. And is that Mrs. Streeter?
25 A. Yes
EFTA01153185
Page 2
1 Q. Mr. Kretschmar, I heard you say before you were
2 sworn in and we went on the record that you hadn't been
3 deposed before. I'm Susan April, we met out in the hallway
4 and I represent a plaintiff in a lawsuit and that plaintiff
5 is named Jeffrey Epstein. And Lilly Sanchez who is with me
6 today is also from Fowler, White, Barnett who represents Mr.
7 Epstein, and you met Mr. King.
8 You will be asked questions by Plaintiff's lawyer
9 and if the Defendant's lawyer wants to ask questions, that's
10 certainly his prerogative. We ask you to let us know if you
11 need something restated or repeated; the court reporter can
12 read things back. If you need to stop, just say you need to
13 stop. You'd like to take a break.
14 As I think you got some tea, if you want anything
15 else or you want to pause to get something, let us know.
16 Okay?
17 A. Do I just say, Can we pause?
18 Q. Yes. You can say, Can we stop.
19 A. Do I raise my hand like we're in school.
20 Q. The only thing I would ask is that if you're in the
21 middle of an answer to a question or if there is a question
22 pending before you break to go to the restroom or anything
23 that you finish that answer so that we're not broke in
24 sequence.
25 A. Understood.
EFTA01153186
Page 3
1 Q. One other thing that witnesses sometime forget,
2 lawyers too, is that because everything you say is being
3 typed and the court reporter can only type one person at a
4 time, let the lawyer who is asking you a question finish
5 their complete question, if you're able to determine the
6 question is over, before you answer; because there is a
7 tendency with some people, they think they know the answer so
8 they say it before the question is completed and that makes
9 the typed record confusing. Okay?
10 If you need anything else, let us know. Okay?
11 A. Okay.
12 Q. Did you know that there was a lawsuit pending that
13 Jeffrey Epstein had filed against Scott Rothstein and Bradley
14 Edwards and someone named LM prior to being subpoenaed in
15 this case?
16 A. No.
17 Q. Are you currently a party in any lawsuit against
18 Scott Rothstein and others?
19 A. Yes.
20 Q. I understand you're represented by counsel and I
21 assume that you've been advised that you do not have to
22 disclose anything that was said between you and your lawyers.
23 So if I ask you a question, I'm not asking you to breach that
24 confidence. So I'm trying to ask questions that don't go
25 there, all right? If you have any difficulty with it or you
EFTA01153187
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1 want it restated, please let me know.
2 WHAT'S the nature of the lawsuit that you're
3 currently in?
4 A. The nature of the lawsuit is: We were defrauded on
5 investments in two of Scott Rothstein's law firms for
6 confident settlements.
7 Q. When you say we were defrauded, who do you mean, as
8 best you can describe it?
9 A. Myself, my family, and there were others.
10 Q. And again, in your own words, how were you
11 defrauded?
12 A. We were sold on the fact that the confidential
13 settlements were real cases, they weren't typical court
14 cases. Many of these settlements were confidential in the
15 nature that they were being handled by two attorneys, you
16 know, outside of having to go to court. And based on various
17 reasons and the plaintiffs wanted a settlement for whatever
18 they were wronged on, and those settlements were timed out
19 over time and, basically, we were funding the Plaintiff
20 getting their money then versus waiting for that timed period
21 to end.
22 Q. How did you hear about this investment in the first
23 place?
24 A. Barry Bekkedam.
25 Q. And it's Bekkedam?
EFTA01153188
Page 5
1 A. Yeah, Barry Bekkedam. I could give it a crack to
2 start off.
3 Q. Don't worry about spelling anyone's name. I'm
4 happy with phonetics and after we're done, you can clarify.
5 A. His firm is Ballamor Capital Management.
6 Q. And how do you know Barry Bekkedam?
7 A. He is dating, used to be a friend of mine, Diane
8 Barnett.
9 Q. So are you saying you met him sort of through
10 social circles?
11 A. Yeah.
12 Q. When you say Diane Barnett used to be a friend, is
13 she no longer a friend of yours?
14 A. No.
15 Q. Did you have a falling-out?
16 A. Yeah, you could say this whole situation has put a
17 bit of a strain on --
18 Q. Does Diane Barnett live in Florida?
19 A. Yes.
20 Q. In Fort Lauderdale?
21 A. Yes.
22 Q. Is she also in the, is she a financial advisor or
23 investment counselor?
24 A. No, she has a real estate license. She worked for
25 the Galleria of Fine Homes I think.
EFTA01153189
Page 6
1 Q. So you met Barry through Diane?
2 A. Uh-huh (affirmative response).
3 Q. And where did you meet him?
4 A. We met out socially. Diane invited me out to have
5 a drink. She wanted me to meet the gentleman that she was
6 involved with.
7 Q. And is that where you got to talking about the
8 business he was in?
9 A. He wasn't, well, his business in the sense of as a
10 money manager but it wasn't the first meeting that I learned
11 about this. It was several meetings after and he also
12 pitched my stepfather.
13 Q. When you met Barry was it here in Florida?
14 A. Yes.
15 Q. And do you know what year that was?
16 A. End of '09. 3rd, probably 4th Quarter of '09.
17 Q. And again, I understand you probably won't remember
18 every detail so my questions are directed to as best you can
19 recall.
20 A. Sure.
21 Q. What do you recall Barry telling you about the
22 investment when you first -- when he first spoke to you about
23 it, the investment that led to you being in a lawsuit against
24 Scott Rothstein and others?
25 A. He told me his firm had done a lot of the due
EFTA01153190
Page 7
1 diligence, was still in the process of finishing due
2 diligence, but he was working closely with George Levin and
3 George Levin's team in doing the background due diligence and
4 that George Levin personally had 600 million into this
5 investment. And that over the past five years there hasn't
6 been any issues, no late payments, everything has been on
7 time.
8 He disclosed that George had one discrepancy on his
9 background which was a kit car company that George owned and
10 there was something of some of the customers felt defrauded
11 and the cars came out late or something, and there was a
12 court case about it, and it all ended up being settled but
13 that was something of, you know, you could find out through
14 your own research that something negative happened.
15 And I've been in business enough that sometimes
16 things happen, customers are, you know, upset and it can be,
17 you know, twisted. So, through Barry explaining through his
18 due diligence and that his teams had done all of this
19 extensive research and looked at some of the books with
20 Levin's company with the investment. Also, meeting with
21 Scott Rothstein, understanding how the investments are
22 confidential in nature, that there was a third party verifier
23 who was Mike Szafranski, that a hedge fund out of New York
24 had requested when they made their investments years before
25 he was put in charge of being an outside verifier that the
EFTA01153191
Page 8
1 funds were in there. That it gave me, you know, some
2 confidence about the investment.
3 Q. Let me back you up a little bit. Do you remember
4 when Barry first told you about this investment before he
5 started talking about due diligence, how did it come up? I
6 mean, were you having dinner, were you at someone's house,
7 where were you?
8 A. I don't remember.
9 Q. Did he just out of know where say I have an
10 investment I want to talk to you about?
11 A. No. I mean, if somebody is a money manager, you
12 know, an investment advisor as he is, in a sense of a
13 balanced-portfolio-type advisor, meaning that he would put
14 your monies in several different low risks to, you know, if
15 you want to do some things that are a little bit more of what
16 would be termed a high risk. I was curious of things that he
17 saw in the market and he was doing middle market financing as
18 as the leverage of banks and so forth were not lending. You
19 know, there's a lot of businesses that just needed cash flow
20 and they couldn't get it from the bank.
21 So it was through conversations that he didn't just
22 bring this one up, he had others that he was, you know,
23 explaining to me. So we, you know, in a sense it was normal
24 that we talked some shop.
25 Q. When he told you about the investment, what did he
EFTA01153192
Page 9
1 call the investment? I mean, we've been calling it the
2 investment. Did he say it's the Rothstein investment?
3 A. Banyon Income Fund.
4 Q. Banyon Income Fund. Is that the fund that George
5 Levin was running?
6 A. Yes.
7 Q. And when he first mentioned it to you, when Barry
8 first mentioned it to you, who else was present?
9 A. Diane Barnett.
10 Q. Anyone else?
11 A. No.
12 Q. So after Barry described this Banyon Income Fund to
13 you, what was the next thing you did, if anything, to invest
14 in it?
15 A. He was pitching my father and I didn't do anything.
16 I was in New York at the time working with a hedge fund, so
17 it wasn't until a little bit later that when my stepfather
18 and I talked and he had, you know, heard about it that I gave
19 it more interest.
20 Q. So you just said your father and your stepfather,
21 is that the same person?
22 A. Yeah, same person. Sorry.
23 Q. What's his name?
24 A. Doug Von Allmen.
25 Q. Do you know how Barry came to know your stepfather?
EFTA01153193
Page 10
1 A. Through Diane. Diane introduced Barry to all of
2 Fort Lauderdale.
3 Q. I see. When you say you were in New York working
4 at a hedge fund, was this like your job at the time or were
5 you up there exploring investment?
6 A. It was a job. I was looking to raise capital for a
7 hedge fund, so I was learning from them about their
8 strategies and what they were all about to be able to speak
9 intelligently to people, but the market had crashed.
10 Everybody's strategies were changing every day it seemed.
11 And it was around April of 2010 I said, you know what,
12 it's -- I'm not jumping into the market of investing
13 MRS. STREETER: April 2010?
14 MRS. APRIL: Let's get that timing right.
15 A. When did I make my investment?
16 Q. Let me see if this will -- I've got something with
17 a date on it.
18 Sir, the lawsuit that I referred to that I asked if
19 you were a party in --
20 A. Uh-huh (affirmative response).
21 Q. -- do you know if that was filed in November of
22 2009? I do have a copy of some pages. Do you happen to
23 know?
24 A. Off the top of my head per date, no.
25 Q. Well, I'm going to show you what is -- This doesn't
EFTA01153194
Page 11
1 show you the file date.
2 MRS. SANCHEZ: That's the amended one.
3 Q. It is a 2210-page document, so I don't have it all
4 in front of me. So let me just show you this and see if it
5 refreshes your memory.
6 Have you ever been a party in a lawsuit before?
7 A. No.
8 Q. I'm going to show you what we call the caption,
9 just the first page that has all the names of the parties of
10 this suit and it goes on to a second page to see if that --
11 And you can see it has a date stamp. And also you'll see on
12 Page 2 it shows you it's not the original.
13 A. Uh-huh (affirmative response).
14 Q. The number of this case is 09-062943 (19). And I
15 don't know if there is any dispute and we have to torture the
16 witness here by asking him to figure it out.
17 MRS. APRIL: Can we all agree that it was filed in
18 2009?
19 MRS. STREETER: Yes. The record will speak for
20 itself.
21 Q. Mr. Kretschmar, you said something earlier and I
22 think you may be off in time and I think your lawyer
23 recognized it. Do you remember if your knowledge of the
24 fraud you mentioned is essentially the same time that it
25 became publicly known that Scott Rothstein's firm had had a
EFTA01153195
Page 12
1 crisis and was falling apart?
2 Do you remember hearing about that just from others
3 or in the news that the Rothstein, Rosenfeld & Adler firm was
4 in trouble?
5 A. Right.
6 MR. KING: Objection to form. It's compound.
7 Q. Do you remember when you heard something about the
8 firm?
9 A. Yes.
10 Q. Do you know about when that was? What time of
11 year? A season or a holiday or something like that?
12 A. Yeah, it was the end of October, like the 31st,
13 going into November.
14 Q. Of what year?
15 A. Had to be 2009.
16 Q. And do you know if you became a party in the
17 lawsuit that I just showed you the caption of? Let's call it
18 for short, the first name is Razorback Funding, LLC. I was
19 going to call it the Razorback suit, if that's okay, versus
20 Scott Rothstein and a number of others?
21 A. Uh-huh (affirmative response).
22 Q. Do you know if you became a party in this suit soon
23 after you learned that the Rothstein firm had a problem?
24 A. Yes
25 Q. So I want to go back and ask you if the dates are
EFTA01153196
Page 13
1 correct in your previous answer.
2 When you first met Barry -- What did you say his
3 name was, Bekk -- I'm going to call him --
4 MRS. STREETER: Bekkedam, B-e-k-k-e-d-a-m.
5 Q. When you first met Barry was it the year before
6 that or was it just a month --
7 A. It would be the ending of '08.
8 4. Thank you?
9 A. And when I left the hedge fund it would have been,
10 you know, March or April of '09.
11 MRS. STREETER: Just answer her questions.
12 Q. And the hedge fund that you left was called what?
13 A. WR Capital Management.
14 4. So do you know when you or your stepfather first
15 put any money into Banyon Capital, roughly?
16 A. May of 2009.
17 4. And this is after you left WR Capital Management.
18 At that time were you employed?
19 A. I don't understand.
20 4. In the Spring of 2009 were you working someplace?
21 A. No.
22 Q. You were just doing your own investments?
23 A. Yeah.
24 Q. So let me go back to that. The year is -- after
25 your initial investment in Banyon Capital was it your
EFTA01153197
Page 14
1 personal investment or was it made through some entity?
2 A. I'm sorry. Could you repeat the question?
3 Q. When you first invested in Banyon
4 MRS. STREETER: Income Fund.
5 MRS. APRIL: Thank you.
6 Q. -- (continuing) Income Fund, was it a personal
7 investment of Dean Kretschmar or did you invest through some
8 entity that you formed. Do you know what I mean?
9 A. Yes, I understand what you're asking. It's either
10 one or the other.
11 Q. If you're not sure, you can tell me that.
12 A. I'm not sure. It could have been my Living Trust
13 or me personally.
14 Q. After the April or May of 2009, did you make any
15 further investment into any opportunity offered by Scott
16 Rothstein or his firm?
17 A. Yes.
18 Q. Can you tell me what that was?
19 A. That was in Razorback.
20 Q. And when was that, if you know?
21 A. That was in July.
22 Q. And --
23 MRS. STREETER: Counsel, are you asking when he
24 made the investment or when he first heard about it?
25 MRS. APRIL: Well, I'm going to ask him the second
EFTA01153198
Page 15
1 question, but I had asked him when you made the
2 investment, actually put money into it.
3 MRS. STREETER: If you're not sure of the dates
4 A. I know when I made my first investment, it was
5 June. It was early June, first or second.
6 Q. I'm not trying to trip you up with these dates
7 I'm just trying to get a time frame generally.
8 So let me ask you this, when did you -- what is
9 Razorback?
10 A. What is Razorback?
11 Q. Yeah. Other than it's a plaintiff on the lawsuit
12 that we talked about? I mean, is it a company?
13 A. Can I speak to you outside?
14 MRS. STREETER: Yes.
15 (WHEREUPON, an off-the-record discussion was had).
16 MRS. STREETER: I just want to put on the record
17 that Mr. Kretschmar is here to answer questions about
18 what happened with regard to the Epstein litigation and
19 the other litigation, the Razorback litigation is an
20 ongoing, pending litigation. And we ask that you
21 refrain from getting into any of those specific details
22 regarding investments that are not relevant and are not
23 reasonably calculated to lead to any evidence in your
24 case in particular. If you could get to this particular
25 issue.
EFTA01153199
Page 16
1 MRS. APRIL: I'll try.
2 (WHEREUPON, an off-the-record discussion was had).
3 MRS. APRIL: I have in case anybody wants to refer
4 to them, including me, some calendars. Sometimes it
5 makes it a little easier to know when things happened.
6 Q. So you invested in something called Razorback?
7 A. Uh-huh (affirmative response).
8 Q. We established that, right. And was Razorback's
9 investment also into the settlements or the kind of
10 settlements you described a little bit earlier with
11 Rothstein?
12 A. Yes.
13 Q. Did you invest after the investment in Razorback
14 any other times with Scott Rothstein in one of these
15 settlement funds?
16 MR. KING: Objection. Form. Vague.
17 Q. Did you ever make any other investment offered by
18 Scott Rothstein after the Razorback?
19 A. No.
20 Q. Did you ever meet Scott Rothstein?
21 A. Yes.
22 Q. Do you know when you first met him?
23 A. At a Boys and Girls Club fundraiser. It was the
24 Boca Resort. It's the car fundraiser where they have all the
25 cars. I forget what it's called.
EFTA01153200
Page 17
1 Q. Do you know what year it was approximately?
2 A. Probably 2008.
3 Q. Did you have any substantive conversation with him
4 at that time
5 A. Nothing.
6 Q. -- about business or anything?
7 A. No.
8 Q. Was there ever a time where you met with Mr.
9 Rothstein and talked about business?
10 A. No.
11 Q. Was there ever a time after the Boca event for the
12 Boys and Girls Club that you met Scott Rothstein?
13 A. Not before the investment.
14 Q. Okay. Let's talk about then the time of the
15 investment. Did you have any face-to-face meetings with
16 Scott Rothstein in 2009?
17 A. Yes.
18 Q. Can you describe as best as you can recall the
19 first -- Was there more than one of those?
20 A. Yes
21 Q. Can you describe to the best of your ability your
22 first face-to-face business meeting with Rothstein about the
23 investment?
24 A. I was there. My father was there. Barry Bekkedam
25 was there. Barry Bekkedam and Ballamor Capital, some of his
EFTA01153201
Page 18
1 people were there. George Levin was there. Frank Preve was
2 there. A.J. DiScala was there.
3 Q. Where is there?
4 A. And Scott Rothstein's personal office in his
5 firm.
6 Q. Had you ever been in his firm's offices before?
7 A. No.
8 Q. Was that over here on Las Olas, an office building?
9 A. Yes
10 Q. And were there any other persons present that you
11 can remember?
12 A. (No response).
13 Q. Let me rephrase that. Even if you can't remember
14 their names, do you think there were other persons in the
15 room?
16 A. Yeah.
17 Q. Can you describe the office to me, in other words,
18 was it a conference room like we're in today or something
19 different?
20 A. It was a combination office and conference room.
21 It had a large sectional couch, a lot of pictures of Scott
22 with various celebrities to governors to presidents. It was
23 elaborate, very nicely built-out office.
24 Q. Was there also a conference table or --
25 A. Yes.
EFTA01153202
Page 19
1 Q. And was it about as big as the one we're at today
2 which looks like it holds about 12 chairs?
3 A. Yes.
4 Q. Was it pretty much filled?
5 A. Yes.
6 Q. What month was that, if you know?
7 A. I don't recall.
8 Q. Let me go back to that later and build to that.
9 How did you happen to be there that day, were you invited by
10 Mr. Rothstein?
11 A. Yes.
12 Q. And was this morning, lunch time, afternoon, did
13 you have a meal or anything?
14 A. I don't, I don't recall
15 Q. Was this meeting in the Fall of 2009? Was a
16 football season?
17 A. Yes.
18 Q. Did some of the individuals who were there, like
19 Barry, travel from out of state to come to the meeting?
20 A. Yes.
21 Q. Did you spend any time with Barry prior to this
22 meeting, social or business?
23 A. I don't remember.
24 Q. You said Barry and Ballamor Capital, that's his
25 firm, right?
EFTA01153203
Page 20
1 A. Yes.
2 Q. Do you remember if he was accompanied by some other
3 individuals from his group?
4 A. Yes.
5 Q. Do you know their names, any?
6 A. Larry Rovin.
7 Q. Is that Rovin?
8 A. Rovin, R-o-v-i-n. I think he's an attorney
9 there.
10 Q. Anybody else?
11 A. Yes, but I don't remember the names.
12 Q. And you don't remember if you, like, went out with
13 that group to dinner or a ball game or on a boat or anything
14 during that visit?
15 A. No, we didn't. We didn't do that.
16 Q. Did you ever go to a Jets/Dolphins game with any of
17 these folks?
18 A. Uh-huh (affirmative response). Yes.
19 Q. Do you know when that was, I mean, was it in this
20 same season?
21 A. Yes.
22 Q. Do you know if during that week you had any
23 conference or meeting with Rothstein?
24 A. Yes.
25 Q. So, not to confuse the issue: Do you know if you
EFTA01153204
Page 21
1 had already met with Scott Rothstein and some other
2 individuals prior to that meeting?
3 MR. KING: Objection to form. Vague.
4 Q. You follow what I'm saying? I can rephrase it.
5 A. Rephrase it.
6 Q. Is it accurate to say you had at least two
7 face-to-face meetings where Scott Rothstein was present?
8 A. Before the Jets game?
9 Q. Ever? At any time?
10 A. Yes, that's accurate.
11 Q. And was one of those before the Jets game?
12 A. Yes
13 Q. And was one after the Jets game?
14 A. Yes.
15 Q. Do you know if it was soon after, the day after?
16 A. Yeah, it was the day after.
17 Q. Who won the game, do you know?
18 A. I think the Dolphins.
19 Q. So, when you first went to Scott Rothstein's
20 office, what was your understanding of the reason you were
21 going there?
22 MR. KING: Is this the first time?
23 MRS. APRIL: The first time.
24 A. We were going to talk more about the confidential
25 settlements.
EFTA01153205
Page 22
1 Q. And this was the first time that you heard Scott
2 Rothstein discussing the confidential settlements?
3 A. Yes.
4 Q. To the best of your recollection, what did he say,
5 in substance? I don't mean word for word.
6 A. I can generalize, but I don't remember word for
7 word what was really talked about, you know, specifics. I
8 mean, it was --
9 Q. Generalized is fine.
10 MRS. STREETER: I don't want you to guess.
11 Q. In other words, did Scott, did he tell you
12 something about the confidential settlements and the process?
13 A. Yes, but it would be more specific to a meeting.
14 The one meeting we had where Barry Bekkedam and George were
15 there, it was more of the foundation of how Barry got there,
16 how George, you know, has been investing, nothing ever
17 tripped up. How we were going to come in and help George, we
18 were going to get a 15 percent return.
19 You know, the meeting after the Jets game, there
20 was a gentleman that flew in to meet Scott who was Thane
21 Ritchey. He was a friend of A.J. DiScala's. He flew in.
22 Scott had invited us to the game, A.J. and I, and we went to
23 the football game. And the next day, it was Thane Ritchey,
24 Michael Legamaro of Morgan, Lewis, Bockius, he had flown in
25 that Tuesday morning, and A.J. DiScala.
EFTA01153206
Page 23
1 Scott at this time was talking about a big case
2 that involved a defendant that had a very large sum of money
3 and had had sex with underaged girls. And he had two girls.
4 Actually, he said it was one at first, very large settlement.
5 And I think the settlement was 18 million.
6 And so that conversation went into with Thane
7 Ritchey, A.J. DiScala and myself and Morgan Lewis and Michael
8 Legamaro from Morgan, Lewis to explain to Michael who A.J.
9 and I soon after hired him to do, you know, the due
10 diligence, you know.
11 Q. Had you ever met Mr. Legamaro before that day?
12 A. No.
13 Q. But you understood him to be a lawyer for Thane
14 Ritchey?
15 A. Yes.
16 Q. And at that meeting -- let me make sure I
17 understand who was there. Mr. Legamaro was there, Scott
18 Rothstein was there, Thane Ritchey, A.J. DiScala and you?
19 A. Uh-huh (affirmative response). Yes.
20 Q. Was there anybody else there from Scott Rothstein's
21 firm for any part of the meeting?
22 A. No.
23 Q. At that meeting was it all talk? Let me rephrase
24 that. Was there just discussion or was there an examination
25 of any documents or materials?
EFTA01153207
Page 24
1 A. No.
2 Q. In the room with you -- were you in the same room
3 that you had been in --
4 A. Yes.
5 Q. -- the other time with the larger group?
6 A. Yes
7 Q. Did Scott at that time name the individual that he
8 was referring to who had sex with underaged girls and one
9 case had been settled?
10 A. No.
11 Q. Did you know from the description who he had been
12 talking about?
13 A. No, I had no idea.
14 Q. And did Mr. Legamaro ask questions of Scott
15 Rothstein about the cases?
16 A. Yes.
17 Q. And at that meeting do you know how long it lasted?
18 and I don't mean exactly but was it an hour, was it all day,
19 do you know?
20 A. A couple hours.
21 Q. And I believe you said a few minutes ago, after
22 that you decided to hire Michael Legamaro, I'm not sure if
23 that's the word you used, retained him?
24 A. Yes, we retained him.
25 Q. Again, who is we in that?
EFTA01153208
Page 25
1 A. A.J. DiScala.
2 Q. What did you retain him for?
3 A. To represent Clockwork.
4 Q. Now, again, your lawyer has asked and I'm trying to
5 respect her wishes and not go into too much about what these
6 entities are, but you mentioned Clockwork. What is Clockwork
7 because I had not heard of them before? Are they another
8 fund?
9 A. (No response).
10 Q. Let me rephrase it, because I'm not trying to make
11 your life difficult. Was Clockwork an existing entity at the
12 time that you engaged Mr. Legamaro, whatever it is? I'm not
13 even asking you what it is, but did it exist or do you know?
14 A. I think that you would have to be, you know, it's
15 our question: Was it or wasn't it?
16 Q. All right. Do you know if you had any formal
17 paperwork, an engagement letter signed with Mr. Legamaro?
18 A. I don't know.
19 Q. Do you know if you paid Mr. Legamaro any advanced
20 retainer fees?
21 A. Yes.
22 Q. And did he represent you after that?
23 A. Yes.
24 Q. And was there ever any time after that that you,
25 again, went to Scott Rothstein's office?
EFTA01153209
Page 26
1 A. Yes.
2 Q. Can you tell me about when it was or how much time
3 elapsed before you went back?
4 A. I think it was the following week.
5 Q. Let me just go back a little, because getting dates
6 down is sometimes important. The ball game you went to the
7 Jets/Dolphins game, was that a Monday night game or Sunday
8 night?
9 A. Monday night.
10 Q. Was it October of 2009?
11 A. Uh-huh (affirmative response).
12 Q. So it looks to me like there was October 5, 12,
13 19th and 26th were all Mondays. So just for frame of
14 reference, one of those, and I guess we could check
15 independently to find out when there was a ball game. One of
16 those you went the next day and that's the first time you met
17 Michael Legamaro at Scott's office, right?
18 A. Yes
19 Q. Did you actually meet him for the first time in the
20 office or did you convene somewhere else first?
21 A. No, I think I met him in the office.
22 Q. And did he bring any other attorneys or paralegals
23 assistants with him?
24 A. No.
25 Q. So then you and A.J. engage him and then you say
EFTA01153210
Page 27
1 there's another meeting some days later?
2 A. Michael came back down, Michael Legamaro came back
3 down and went to Scott's office with A.J.
4 Q. And do you know the purpose of that visit?
5 A. Michael was doing due diligence on RRA, on
6 Rothstein's firm, and wanted to spend more time with Scott
7 Rothstein understanding these investments.
8 Q. Were you there at all?
9 A. No, Not that meeting.
10 Q. Did A.J. discuss with you what occurred at that
11 meeting?
12 A. In general, he discussed that Michael and Scott
13 met. They got along. Michael understands the nature of the
14 settlements. Everything was going well. Michael had a lot
15 of questions for him and was continuing to investigate and do
16 due diligence on the investments of RRA, et cetera.
17 Basically, it was going well.
18 Q. Do you know if you saw Michael Legamaro at all
19 during that trip he made down here?
20 A. I don't remember.
21 Q. Did you see A.J.?
22 A. Yes.
23 Q. Do you know if -- did A.J. say whether Mr. Legamaro
24 in that visit to the Scott Rothstein office looked at any
25 documents and/or saw any materials?
EFTA01153211
Page 28
1 A. I don't remember.
2 Q. Was there any time after that that you yourself,
3 again, went with to Rothstein's office?
4 A. Yes.
5 Q. And do you know approximately what date or how much
6 time elapsed from this meeting you just described that you
7 didn't go to?
8 A. I think a week.
9 Q. So about a week later you go to Rothstein's office?
10 A. Uh-huh (affirmative response).
11 Q. And who else is there?
12 A. A.J. DiScala, Michael Legamaro.
13 Q. Anyone else. Thane Ritchey there?
14 A. No.
15 Q. Was Thane Ritchey -- Okay. He wasn't there.
16 So just the four of you were at that meeting?
17 A. As I recall.
18 Q. And what occurred at that meeting?
19 A. Scott was trying to close this deal which was the
20 first case. He then told us that the sister of this girl was
21 also involved with this client as well as at this point he
22 told us several girls now, once the first girl went forward
23 and started working with him, he was getting calls from other
24 girls saying that I, too, was, you know, involved with this
25 client. And so --
EFTA01153212
Page 29
1 Q. When you say the client, you mean the law firm --
2 A. I'm sorry, the defendant. And so Scott was all
3 fired up saying we've gotta get the first one. We've got a
4 total of 18, you know, girls and now we've got the first one
5 that we need to close, but now the sister, you know, he can
6 get the sister negotiated and taken care of.
7 At this point it was -- we were, I'm trying to
8 understand the whole deal. It was a large sum of money. At
9 this point we were calling it bullshit. How can one person
10 get a settlement for 18 million.
11 So Scott at this point said, Okay, you guys are
12 here. I'm going to trust you. I'm going to open the case.
13 I'm going to bring it down and I'll let you see who this
14 person is.
15 At this point Thane was also, you're talking about
16 maybe a two-week time period of, you know, Thane was talking
17 about making a $5 million investment. So Michael was already
18 in the process of doing his due diligence and things that he
19 needed to do. So Scott called for the evidence of who this
20 person was. We were in Scott's office, his personal office
21 in R.R.A.. And 10, 15 minutes later in walks our former
22 Sheriff Ken Jenne, with another gentleman, I didn't know who
23 he was, bringing in several boxes which ended to be I think
24 about 19.
25 Q. Were the boxes marked or numbered?
EFTA01153213
Page 30
1 A. Huh --
2 Q. You know times boxes say 1 of 10, 2 of 10? I mean,
3 any numbering like that?
4 A. I don't remember.
5 Q. So Mr. Jenne walks in with someone else with the
6 boxes, and what does he do?
7 A. They start bringing all the boxes and they start
8 laying them, you know, as you walk in there was a, you know,
9 almost if you walked into this room, he was putting all the
10 boxes against the wall here and they were stacked. What
11 ended up being 19 boxes. So it was a lot of information.
12 Q. Were these like banker's boxes that you put files
13 in?
14 A. Yes. Yes.
15 Q. Then what happened? Did Jenne leave?
16 A. Yeah, he left. Scott had pulled some certain
17 information from the case files and said, you know, I'm going
18 to tell you about who he is. I need the utmost confidence in
19 this as this is an open case. It's an ongoing case. This
20 person has other issues. He's just getting out of -- either
21 he was in jail or just getting out of jail. So he kind of
22 set the stage of who this person was. He already had a track
23 record. He already had issues. It was already public. You
24 could Google it.
25 And these girls that came forward would not come
EFTA01153214
Page 31
1 forward before and that was the, you know, confidential
2 nature of, you know, Scott saying I've got 18 of these girls
3 lined up and here is this person. His name is Jeffrey
4 Epstein.
5 Q. And at that moment had you heard of Jeffrey
6 Epstein?
7 A. No.
8 Q. Had the others who were there in the room
9 commented, you said that A.J. DiScala was there?
10 A. Uh-huh (affirmative response).
11 Q. Did he act like he knew who Jeffrey Epstein was?
12 A. I don't think any of us knew who he was.
13 Q. So what happened after Scott said that?
14 A. Scott had some flight records I guess from Jeffrey
15 Epstein's plane or planes, I don't know if there were
16 multiple, but there were flight records It seemed to be
17 from, you know, a company that took the logs of them. Again,
18 I don't know if it was his actual company or the flight
19 company.
20 Scott started talking about some of the issues of
21 why he was going to be able to get these large sums of money,
22 number one. This gentleman, Jeffrey Epstein, is supposed to
23 be -- Scott said he's got over a four and a half billion
24 dollar networth of what Scott could -- what was kind of known
25 publicly. There were also people on these plane rides that
EFTA01153215
Page 32
1 were known figures that definitely would not want this
2 information getting out and that the nature of the settlement
3 would, they would want to -- Jeffrey Epstein would want to
4 keep this quiet and that there was already pressures on him
5 to keep it quiet.
6 Q. Would want to keep what quiet?
7 A. The fact that there were underaged girls on these
8 planes, and there were other people on these planes and they
9 were public figures.
10 Q. Did you actually see these supposed flight logs?
11 A. Yes, a few of them.
12 Q. Did you recognize any names on them?
13 A. Yes.
14 Q. Can you say who any of them were?
15 A. Bill Clinton. Naomi Campbell, which I think she's
16 a super model. There was a reported Sheik, I don't remember
17 who it was but, obviously, an important person, a very
18 wealthy person.
19 Q. And it's your understanding that on these plane
20 trips there were underaged girls?
21 A. Yes.
22 Q. Did you find out the names of any of the girls?
23 A. No, but I remember Scott was explaining because all
24 the other people had their names written out but the girls,
25 it was just their first name and the first letter of their
EFTA01153216
Page 33
1 last name. So if it was Sara, Sara something, it was Sara C.
2 Q. I see. So, there were these boxes in the room.
3 And were these flight logs removed from the boxes that Mr.
4 Jenne and the other gentlemen brought in or did Scott have
5 those separate?
6 A. Scott had those separate.
7 Q. Did he show you anything else by way of materials?
8 A. Yes. But they were, I think they were pieces of
9 his former accusations of former, you know, arrest records
10 and news clippings and some other things.
11 Q. Did you have a look at some of those?
12 A. Very quickly.
13 Q. Did anybody else in the room with you scrutinize
14 them more closely?
15 A. Yes.
16 Q. Who?
17 A. Michael Legamaro with Morgan, Lewis, Bockius, the
18 attorney.
19 Q. Do you know what City Mr. Legamaro bases his
20 practice in?
21 A. Chicago, Illinois.
22 Q. Did you ever visit him there?
23 A. No.
24 Q. Did Mr. Legamaro comment about any of the items
25 that he looked at in your presence in front of Scott
EFTA01153217
Page 34
1 Rothstein?
2 A. Oh, yeah.
3 Q. Can you tell us what he said then?
4 A. Yeah, he went through the boxes. Scott said you
5 guys can look at the boxes, just don't take any of the
6 information, don't pull it out and misplace it from the
7 files.
8 So Michael Legamaro did spend, you know, some time
9 looking through a lot of the boxes and the files and said,
10 you know, This is a real case. And he explained that as a
11 young attorney he used to be an attorney for the United
12 States and I think he termed it as a jag attorney, which I
13 don't really know what that stands for, but he used to
14 prosecute for -- I think he said -- child molestation,
15 underage, you know, things of this nature which are -- I
16 don't know the word I'm looking for.
17 Q. Abuse?
18 A. Yeah, abuse. I would just put heightened concern,
19 you know, touchy subjects. I don't know if that's the --
20 Q. So he told you something about his past experience
21 with cases of that nature?
22 A. Yes. He gave in that description, gave us
23 confidence that he knew what he was looking at.
24 Q. Did he ask for copies of anything that he looked
25 at?
EFTA01153218
Page 35
1 A. I don't think so.
2 Q. Did he make any notes such as we --
3 A. I don't remember.
4 Q. You said he made a remark along the lines of this
5 is a real case. Did you understand he only was looking at
6 one case?
7 MR. KING: Objection. Leading.
8 A. Repeat the question.
9 Q. Did you understand, do you know if he looked at
10 more than one case file?
11 A. I don't know.
12 Q. Do you know if Mr. Legamaro, do you know how at
13 that time he was able to confirm that this is a real case?
14 A. I'm not an attorney. I don't know.
15 Q. Did he have a laptop with him?
16 A. I don't remember.
17 Q. Do you recall him at any time whether on his own
18 computer or one made available to him where he punched up
19 some numbers to look at any of the cases online, if you
20 remember?
21 A. That's a good question.
22 MRS. STREETER: Don't guess.
23 A. I know. I don't remember.
24 Q. Do you know how much time you spent at the
25 Rothstein office that day when Michael Legamaro was looking
EFTA01153219
Page 36
1 at these files?
2 A. Hour and a half, two hours max. We had Thane
3 Ritchey on the phone.
4 Q. Oh, Okay. Was he on the phone the whole time?
5 A. Not, not the whole time.
6 Q. Was there any other conversation other than what
7 you've described between Scott Rothstein and any of you at
8 that gathering?
9 A. I'm sorry. Ask again.
10 Q. Other than what you've already testified to about
11 what Scott said and what Mr. Legamaro said, do you recall any
12 other conversation that occurred at that gathering?
13 A. (No response).
14 Q. For example, you said Mr. Ritchey was on the phone.
15 Did he ask questions?
16 MR. KING: Objection. Compound. Unless you're
17 just focusing on that last question.
18 Q. Well, did he ask any questions? Let's focus on
19 that one.
20 A. He did. I don't remember specifics.
21 Q. Is there anything else that was said by anybody at
22 that meeting that you remember today concerning the
23 settlements or Mr. Epstein that you haven't already testified
24 about.
25 A. Yes, at that meeting A.J. DiScala had disclosed
EFTA01153220
Page 37
1 that his friend Ted Waite is dating the girl or a girl that
2 used to date Jeffrey Epstein, and that he knows from prior
3 conversations with Ted that Jeffrey wasn't the, you know, was
4 kind of known to be a, you know, womanizer, a cheater, this
5 kind of -- this would fall in line with his character. A.J.
6 Said he was going to call Ted and see if he could talk to
7 Ted's girlfriend.
8 Q. Did A.J. say that in front of Rothstein?
9 A. Yeah.
10 Q. And do you know if A.J., did A.J. ever tell you
11 that he did speak to Ted Waite or the girlfriend?
12 A. Yes.
13 Q. What did he tell you about that?
14 A. He spoke to Ted. Ted got really pissed off at
15 him.
16 Q. At A.J.?
17 A. Oh, yeah.
18 Q. Because?
19 A. He just felt that from what A.J. said to me, he
20 just felt A.J. was out of line and, you know, he didn't want
21 his girlfriend being questioned about, you know, this stuff
22 and to, you know, mind his own business.
23 Q. And did he, as far as you know, after that not
24 involve the girlfriend?
25 A. I don't know.
EFTA01153221
Page 38
1 Q. Do you know her name?
2 A. No.
3 Q. Did you ever meet this Ted Waite?
4 A. Yes.
5 Q. Does he live in New York?
6 A. No, he lives in San Diego.
7 Q. Have you ever met the girlfriend of Ted Waite who
8 used to be Jeffrey Epstein's girlfriend?
9 A. No.
10 Q. Anything else that you recall that was said during
11 this meeting that you haven't already testified about?
12 A. Not that I can think of.
13 Q. If you remember, at the conclusion of this meeting
14 was there any decision made about you going forward with the
15 investment or requiring additional time to decide?
16 A. It was our conclusion really based off of Michael
17 Legamaro's feelings, comments and, you know, him being a
18 respect -- what I thought was a respected attorney from a
19 very respected firm. He had high confidence this is a real
20 case and, you know, it could be that there are several of
21 these cases that we
DataSet-10
Unknown
92 pages
• ,I Condensed Transcript
• IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, FLORIDA
L.M.,
Plaintiff,
vs. Case No. 502008CA028051
XXXXMB AD
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LARRY EUGENE MORRISON
TAKEN ON BEHALF OF THE PLAINTIFF
VOLUME I
Pages 1 to 200
October 6, 2009
10:55 a.m.
515 N. Flagler Drive
West Palm Beach, FL 33401-4321
court reporter
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EFTA00181381
Larry Eugene Morrison - Volume I October 6, 2009
1 3
• IN /NS CIRCUIT COURT Of TAR 15Th JUDICIAL CIRCUIT IN
AND PM PAIN BRACH COUNTY. FLORIDA
VOLONE I Pages 1 to 200
2
3
4
APPEARANCE OF COUNSEL
On behalf of the Defendant
ATTEFOURY. GOLDBERGER A WEISS
BY: JACK ALAN GOLDBERGER. ESO..
250 Australian Avenue
Suite 1400
5 act. FL 33401
Plaintiff. I 6
/Case No. 5020006020051
IX/WM AD On behalf of the Defendant by telephone:
JRFPRRY DITHER. e
BURMAN. CRITTON. LUTTIER & COLEMAN
Defendant . I 9 BY: MICHAEL J. PIKE. ESO..
515 N. Fla or Drtve
10 Suito 400
DEPOSITION OF lm ad,. FL 33401
LARRY MAUNA NORAISON 11
TAKEN On SHALT OF INA PLAINTIFF
October 4. 2009 12
10/59 a.m. - 2/20 p.m. 13
On behalf of the witness:
515 X. ?kegler Drive
Nest Palm Beach, FL 13401.4121 14
LAW OFFICE OF BRUCE E. REINHART
15 BY: BRUCE E. REINHART. ESO..
One Clearleke Cantor
16 250 S. Australian Avenue
Suite 1400
court reporter 17 &ch. FL 33401
16
19
20
21
22
23
24
25
2 4
• 1
e
I
4
APPEARANCES OF COUNSEL
On banal a the Flambe L.M..
ROTHSTEIN. 110SENFELDT a ADLER
BY: BRADLEY J. EDWARDS. ESO.
111X1MICHAEL WHEELER. ESO..
401 East Las OHS 130.40Velt1
1
2
3
4
5
WITNESS:
INDEX OF EXAMINATION
LARRY EUGENE MORRISON
Page
S41[91650 6 DIRECT EXAMINATION
ran Lo, ie. FL 31394
By Mr. Edwards #5
7
CROSS-EXAMINATION
s By Ms. Ezell *190
On betel d Planter Jane Doe 2 through
T 9 CROSS-EXAMINATION
mERUELSTE1N 6 HOROWITZ. PA By Mr. Willits #195
10 BY: JESSICA D. ARBOUR. ATTORMEY.AT4AW. 11)
19205 Beware Boulevard
11 Suite 2218 CROSS-EXAMINATION
Men. 1-1. 33160 11 By Mr. Pike N196
12 12 FURTHER REDIRECT EXAMINATION
By Mr. Edwards #199
li On Denali of mantes Jane Doe 101 aro 102 by 13
telephone: 14
15
PODHURST ORSECK PA 15
16 BY: KATHERINE W. EZELL. ATTORNEY.ATiLAW.
25 W. Ragier Street 16 INDEX TO EXHIBITS
17 17
Plaintiffs
IS Page
18 Exhibit Desolation
On banal of me Plartlf C.MA by telapheac 19 1 Twenty-four pages of 'JEGE. Inc..
20 Passenger Manifest.' *138
LAW OFFICE OF RICHARD WILLITS. PA 20
St BY: RICHARD WILLITS. ESO.. 21
2290101h Avenue N.
21 Suite 404 22
Laks Worm 33481 23
21 24 (Plaintiffs Composite 1 was attached to the
25 original transcript and copies of the transcript.)
25 25
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1
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Deposition of LARRY EUGENE MORRISON
October 6. 2009
THE REPORTER: Do you swear the testimony
1
2
3
4
You know. it was a business decision made somewhere.
O. What does the company do?
A. What? The company? It's just a holding
company, I think, for the aircraft. It's not -- I
•
5 you're about to give will be the truth, the 5 don't believe it to be a money making company or a
6 whale truth. and nothing but the truth so help 6 real corporation.
7 you God? 7 O. You're saying 'tor the aircraft* I'm
8 THE WITNESS: So help me God. 8 interpreting that to mean you're talking about one
------- 9 aircraft.
10 LARRY EUGENE MORRISON, having been first 10 A. Correct.
11. duly sworn, was examined and testified as 11 O. Does that mean there's one or there's more
12 follows: 12 than one?
13 DIRECT EXAMINATION 13 A. There's more. He owns more than one, but
14 BY MR. EDWARDS: 14 justoneis JEGE Of --
15 O. Tell us your name. 15 O. And the aircraft that he owns, how many of
16 A. Larry Morrison. 16 those do you either service and/or ride on?
17 O. And, Larry, where are you employed right now? 17 A. I used to. I haven't been — Actually, I
18 A. For JEGE. 18 stepped back from being physically involved, just •
19 O. What's JEGE mean? 19 now I just do paperwork • and it was February of
20 A. It's the aviation flight department for 20 2007. So I haven't actually physically been on the
21 Mr. Epstein, and my primary job is Dankjold Reed 21 airplanes other than I will take the Boeing for
22 Aviation. 22 maintenance.
23 MR. REINHART: Spell it. 23 O. Since it seems like we've kind of skipped
24 A. D-A-N-K-J-O-L-D, and then the second word 24 ahead from 2001 to 2007, am I right that your first
25 is Reed, R-E-E-D. Aviation. Its a corporate flight 25 involvement with Jeffrey Epstein of any way, shape, or
6 8
1
2
3
4
department.
O. What do you do for him?
A. Director of Maintenance.
O. Okay, so you maintain his planes --
1
2
3
4
form was 2001?
A. That's correct, yeah.
O. You didn't meet him before that.
A. I had met him. He was a -- He was an
•
5 A. Correct. 5 associate of my previous boss.
6 O. should something go wrong? 6 O. Who's that?
7 A. Correct. Yes. Yep. 7 A. Mr. Wexner.
8 O. Do you also — 8 O. -Wexner?
9 A. For maintenance. 9 A. Yes.
10 O. Do you also fly on his planes? 10 O. How do you know Wexner?
11 A. On Mr. Epstein's? 11 A. I worked for Limited Stores for 12 years.
12 O. Yes. 12 O. Doing what?
13 A. I used to. I was a flight engineer -- 13 A. Essentially the same thing - aircraft
14 O. Okay. What -- 14 maintenance for their corporate flight department and
15 A. -- on his 727. 15 flight engineering on the 727.
16 O. When you list your company - JEGE? 16 O. How many aircraft did Wexner have?
1? A. Yes. Yeah, ifs just initials. It's an 17 A. Well, none that I know that he had
18 LLC or holding company. 18 personally, but the corporation had - the flight
19 O. How long has that holding company been around, 19 department operated - we had three Gulfstreams, two
20 if you know? 20 Hawkers, and a 727.
21 A. Since — I think it was developed when I 21 O. What was the name Of his Corporation that
22 came with the airplane • 2001. 22 maintained the aircraft?
23 O. Whose idea was it for that to come about • was 23 A. For Limited Stores?
24 it yours? Was it his? 24 O. Yes.
25 A. Oh, no. no, somewhere -- It wasn't mine. 25 A. It was just -- It was called Limited -
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Limited Flight Department.
O. And do you know him personally then --
Wexner?
A. Yeah, I had met him, of course, you know.
1
2
4
3
O. Yes.
A. Aircraft technician.
O. Which entails what?
A. Maintenance of any or all of the aircraft
5 I met him. I used to do aircraft completions for 5 operated by the flight department and some flight
6 him, so which would involve personal meetings. 6 mechanic duties.
7 O. When did you first meet Wexner? 7 O. What kind of airplanes?
8 A. 1988 was when I hired on, so I don't 8 A. Gulfstreams, Hawkers.
9 remember the month. 9 O. How big is the Gulfstream?
10 O. How did you get that job? to A. Fifteen passenger - 15 to 17.
11 A. Through word of mouth and, you know. I 11 (Mr. Goldberger exited.)
12 worked - I lived in - been in aviation for years in 12 BY MR. EDWARDS:
13 Columbus. 13 O. What did Wexner use the Gulfstream for?
14 O. Well, I mean, I= Wexner's an important la A. They were division airplanes. mostly.
15 person, right? I mean, he -- 15 O. And the other airplane you named - what did he
16 A. Correct 16 use that for?
17 MR. GOLDBERGER: Form. 17 A. Same, same.
18 BY MR. EDWARDS: 18 O. Any idea why he had two planes?
19 O. He's somebody who owns - my understanding - 19 A. Well, I mean, yeah, we used them - they're
20 Limited, Victoria's Secret? 20 a tool. It wasn't him. It was a large Fortune 500
21 A. Well, he doesn't own them. He's Chairman. 21 company. They use them as tools to -- You know,
22 you know. 22 Limited has control over 60 percent of their
23 O. Chairman of -- 23 manufacturing processes. plus, you know, what, 1200
24 A. Yeah. He doesn't personalty own it. It's 24 stores, or whatever, throughout all their divisions.
25 a publicly held company. 25 I mean, when you say "Limited,* it's not
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O. Where were you prior to any involvement with
MI Wexner?
A. I worked for Red Roof Inn True Sports
Flight Department.
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just Limited, d's Victoria's Secret and it was
Express and Lemers and Henri Benders and all of
that back then, so, I mean --
O. 50 —
5 O. How did that position lead you to A. -- we moved a lot of passengers to keep
6 Wexner? 6 those stores for the retail business.
7 A. Well, it was always known that Limited 7 O. And by *passengers.' do you also mean clients
8 Flight Department was one of the best jobs in 8 of his?
9 Columbus and, actually, several other people that 9 A. That I don't know. No. Mostly we just
10 were already there knew me from previous jobs and 10 dealt with upper echelon, you know, people in the
11 education - we went through aircraft mechanic, or A&P 11 retail businesses from --
12 school, together - so when the position became 12 O. Such as whom?
13 available they pointed to me and - absolutely. It 13 (Mr. Goldberger entered.)
14 was a line organization. 14 A. Can't even remember names, but it would be
15 O. So did Mr. Wexner approach you or did you is -- We would take buyers to Europe in the spring and
16 apply to him or how did that work? 16 fall. They would buy samples and bring them back to
17 A. Oh, no, no, no. It's -- No. He wouldn't 17 analyze for marketing. We would hire -- We would -
18 be involved in that type of activity. You apply to 18 Division heads, when they would do store shops and,
19 H.R. and you interview with the Director of 19 Real Estate, we take Real Estate out when they were
20 Operations or the Chief Pilot. You know, he 20 looking for new real estate.
21 wouldn't. 21 O. While you were working back in '88 -- Well,
22 O. So you start with Wexner in 1988. 22 how long overall did you work with Wexner and/or
23 A. Yes. 23 his companies?
24 O. What do you do for him then? 24 A. Well, '88 through when I camp hero in
25 A. What did I do for him? 25 January of '01.
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O. Why the change?
A. It offered an opportunity -- Well, one was
I enjoyed flying • and the 727 was being replaced by
a BBJ, which is a two•man airplane, not a three-man
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aircraft. I mean, whatever it takes to keep a
corporate flight department operating.
O. Did you know back then of his relationship, if
any, with Jeffrey Epstein?
•
5 airplane - three-pilot airplane - and it gave me the 5 A. Not immediately, no.
6 opportunity to become a Director of Maintenance, and 6 O. When is the first time that you knew of a
7 it was a challenge. You know, bringing - upstaging 7 reputation or a relationship between Wexner and Epstein?
8 an airliner on a private ticket or a VIP ticket is a A. Would have had to probably be around maybe
9 really challenging, and I enjoy the challenge of 9 '98, 99.
10 working and developing the program and stuff. 10 O. How do you become aware that they know one
11 O. Well, my understanding, Wexner is 11 another?
12 generally - he's in Ohio, right? 12 A. Because Jeffrey. every one That's when
13 A. No, he's got other places. I mean -- No, 13 I became a flight engineer on the Boeing. and every
14 he's like anyone, he's - in his category - he's got 14 once in a while Jeffrey would ride on the Boeing,
15 multiple homes and -- 15 that's all • that's all I knew.
16 O. Well, when you would maintain his aircraft, 16 O. How did it come about that he would ride on
17 would that be in Ohio -- 17 Wexner's Boeing?
18 A. Yes. We were based -- 18 A. They were business associates, I think.
19 O. Or elsewhere? 19 O. As far as you know, they were business
20 A. We were based at Lane Aviation. 20 associates.
21 MR. REINHART: Hold on one second. You 21 A. Right.
22 have to let him finish asking the question 22 O. Did you understand the business relationship
23 before you answer. 21 between the two?
24 THE WITNESS: Okay. I'm sorry. 24 A. Welk I believe it's public knowledge
25 BY MR. EDWARDS: 25 that, I think, Jeffrey managed Mr. • some of Mr.
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O. I'm sorry, have you ever had your deposition
taken before?
A. No.
O. You definitely never had your deposition taken
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Wexner's funds.
O. Is that something that Mr. Wexner told you?
A. No.
O. Is that something that somebody of Mr.
•
5 before while somebody else is trying to eat at the same 5 Wexner's organization would have told you?
6 time they're trying to ask the questions that's very 6 A. No.
7 bizarre. 7 O. Is that something that Jeffrey Epstein told
A. Yes, yes. 8 you?
9 O. I meant to do this before I got here. But. 9 A. No.
10 regardless. Ill wail until you finish your answer before 10 O. Is that just reading articles that speculate
11 I ask my next question; you do the same thing. 'Uh-huh' 11 as to the business relationship between the two or do you
12 or 'uh-uh.' they kind of look the same on the record. so 12 got something more for me?
13 try to give us a 'yes' or 'no' or something we 13 A. No, it's just • it's speculation and, you
14 understand. 14 know, what I've read. you know.
15 A. Alright. 15 O. I mean, like you say, to me it's common
16 O. II I ask a question that was a bad question or 16 knowledge --
19 something you don't understand - I've asked bad questions 17 A. Right.
18 before • say, I don't gel it? I'll ask a better 18 O. But It's only because of what I've read. I
19 question. 19 don't have a specific person that I could cite to to say
20 A. Okay. 20 that, do you?
21 O. You were working with = Wexner. You got 21 A. Right. No, just - just periodicals.
22 the job there starting in 1988. On a day-to-day basis, 22 O. What's your understanding of the personal
23 what would you be doing? 23 relationship, if any, between Wexner and Epstein?
24 A. Maintenance, aircraft maintenance, 24 MR. GOLDBERGER: Form.
25 tracking of aircraft maintenance. cleaning of 25 A. Don't know.
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O. Did you ever know of a time -- And I may be
asking a question that would just be completely outside
of your knowledge, so let me back up.
Have you ever stayed at Wexner's house?
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O. Have you spoken personally with Mr. Wexner?
A- On business issues, yes.
O. Business issues related to your work on Ns
airplanes?
5 A. No. 5 A. Correct.
6 O. Do you know where his house is? 6 O. Have you spoken to him on any other issues
7 A. Yes. 7 that don't involve business relationships with his
8 O. Do you know what the address is in Ohio? a airplanes?
9 A. No. I just know the city. 9 A. No.
10 0. Do you know who he lives with? 10 O. Because you're Nred basically for that
11 A. Yes. 11 purpose, so that's kind of how you deal with him.
12 O. Who is that? 12 A. Yeah. Ifs I'm an employee and he's my
13 A. His wife and children. 13 employer and I only deal with him. you know. on
14 0. What's his wiles name? 14 issues that Involve maintenance.
15 A. Abigail. 15 O. I think I probably know the answer to the next
16 O. Abigail Wexner, and he has three or four 16 question, but just in case I dont do you know any of
17 daughters, right? 17 his personal friends • people that he would hang out with
18 A. No. Has got a son. Harry. and two 18 on a social level - being Mr. Wexner?
19 daughters. I think. 19 A. Through my business ties, yes, yes.
20 O. A son and two daughters. 20 O. Who's that?
21 A. I don't know. See. that was back in 2001. 21 A. I'm trying to remember -- You have to
22 I don't know what they have - if they have more kids 22 remember ifs been several years.
23 23 O. Right.
24 O. Okay. Did you ever hear any Information that 24 A. He was friends with the Tuckennans.
25 he was homosexual? 25 O. What's Mr. Tuckerman or Ms. Tuckerman's names?
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A. No.
O. Being Mr. Wexner.
A. No.
O. Any indication to you that he may be
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A. Ms. -- I caret I always addressed them
by their proper name.
O. Do you know what they do?
A. They owned an optical company - opticians.
5 homosexual or bisexual? They were high school friends from Mr. Wexner's high
6 A. Absolutely not. 6 school days.
7 O. Have you heard any information that he and Mr. 7 O. In Ohio or New York?
8 Epstein were involved sexually with one another? a A. He went to high school in Bexley.
9 A. Oh, no. no. 9 O. Bexley. Ohio.
10 O. Would that surprise you? 10 Has he ever discussed with you how
11 A. Absolutely. 11 longstanding the relationship is between himself and Mr.
12 O. And Mats only because you know him and you 12 Epstein?
13 know Mr. Wexner and you don't see the Iwo together. 13 MR. GOLDBERGER: Form.
14 A. Correct. 14 A. I don't understand. Can you rephrase it?
15 MR. GOLDBERGER: Form. 15 O. Well, you know that at some point in time -
16 A. Welt - 16 You started working with him in 1988. The first time.
17 O. He -- 17 according to my notes. that you became aware that he was
18 A. Go ahead. 18 friends or acquaintances with Mr. Epstein was '98 -
19 MR. REINHART: If you need to answer. 19 almost ten years later.
20 answer the question. 20 A. Right.
21 A. Yeah. No. I saw him with Sharon. which 21 O. After you became aware that there was that
22 was his previous girlfriend before he met Abigail. 22 relationship, whether business or otherwise, did he ever
23 O. Right. 23 speak to you about how long he had known Mr. Epstein?
24 A. No. There was never any hint or anything 24 A. Oh, no, no.
25 that I would even conceive that. 25 O. So as far as you were concerned, 1998, when
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you found out there was a relationship with Epstein. it
could have very well started then.
A. Yes.
O. Aside from aircraft technician and taking care
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O. Who were some of the pilots?
A. Tun Staley. Jim Taylor. They've had some
turnover too. I don't know who all is still there
because retail is down.
•
5 of Mr. Wexner's aircraft back in the '805 and, I guess. 5 O. Was Larry Visoski a pilot used by MI
6 early '90s, did you have any other personal involvement 6 Wexner at any time?
'7 with him? 7 A. No.
8 A. Just on aircraft completions. O. How about David Rodgers?
9 O. And when you would speak with him, would that 9 A. No.
10 be over the telephone. at the airport. at his private -- 10 O. Are those names you're familiar with?
11 A. It would usually be al the corporate 11 A. Yes.
12 office. 12 O. Those we names you're familiar with how?
13 O. Al the corporate office? 13 A. I flew with them when I was flying for Mr.
14 A. At the corporate office. 14 Epstein.
15 O. Can you tell me the address for his corporate 15 O. So there's no real, other than yourself
16 office? 16 Welt, tell me if I'm wrong: I understand that you did
17 A. No, I can't. 11 some work for Mr. Wexner related to his aircraft and you
18 O. If I requested that from your attorney, would Is did some work for Mr. Epstein, which we haven't yet got
19 you be able to get that information? 19 to, but you did some work for him too. Are there any
20 A. Well, I mean. I imagine it's public 20 other people that have that type of relationship with
21 knowledge • wherever • it's at the Limited. 21 both parties?
22 O. And that's where you would meet him • at the 22 A. No. I'm sorry, resay that.
23 Limited? 23 O. Okay. You've already told us that you were
24 A. Yeah. 24 the aircraft technician for Mr. Wexner.
25 O. And how often was • you know, I know that 25 A. One of them. One of several, yes.
22 24
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we're talking about 15, 2O years ago - how often was Mr.
Wexner personally at that location at the Limited
offices?
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O. One of them. Then you also have knowledge
about Mr. Epstein and some relationship with Mr. Epstein.
A. Correct.
•
4 A. I have no idea. 4 O. Are there any other pilots, aircraft
S O. But any time you needed to talk to him. that's 5 technicians, people like that that you know of to have a
6 where he would be? 6 relationship with both Mr. Wexner and Epstein?
7 A. Yeah, and I usually went to Charlie A. No, no.
8 Hinson. 8 O. Do you know how Mr. Wexner met Mr. Epstein?
9 O. Who's Charlie Hinson? 9 A. No.
10 A. He was the president of the stores. He to O. How long - if you started in 1988 • how long
11 basically was my gobehveen for these aircraft 11 did you stay with Mr. Wexner and/or The Limited?
12 completions for the design. 12 A. January of '01.
13 O. And you mentioned the Gullstream as an 13 O. Why did you stop?
14 aircraft. Did you also serve as a technician for other 14 A. Because what we were talking before, you
15 aircrafts that were owned by Mr. Wexner? 15 know, I wanted to continue flying. They bought a
16 A. Right, but not Mr. Wexner. They're owned 16 BBJ. which is a two-pilot aircraft, and I wanted to
17 or operated by Limited Stores. 17 continue flying. Mr. Epstein bought the 727 and
18 O. Limited Stores? 18 offered me a position to continue flying and. you
19 A. Right. Yes. 19 know, basically sot up the airplane for his flight
20 O. What did you do for them? 20 department because they hadn't had any previous large
21 A. Same • maintenance. 21 aircraft experience.
22 O. Did you ever fly in them? 22 O. I missed something. It wasn't your fault, it
23 A. On the Guffstreams in the early days we 23 was mine.
24 used flight mechanics, especially on international 24 The Gulfstream that you were talking about.
25 flights. 25 did you used to fly that as well as being a flight
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technician?
A. No, no.
O. Okay.
A. You don't have to have a flight - a
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0. Do you know why Epstein those to buy that
particular 727 rather than one of the other million 727s
that are made?
MR. GOLDBERGER: Form.
5 pilot's certificate to be a professional flight 5 A. Because it was probably the finest one out
6 engineer. I've got a turbo - a flight engineer turbo 6 there •-
7 jet rating, but you don't have to have a commercial 7 0. Why?
B ticket as long as you - the FAA recognizes your heavy 8 A. -- In all honesty. It's got a fully Paged
9 aircraft maintenance experience. 9 STC interior with EFTS cockpit, and Limited's
10 0. So you're saying that if the FAA recognizes
DataSet-10
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Subject Priveleged and Confidential
June 14, Tuesday
7:30 Breakfast A t w/lan Osborne & Michael Wolff (Michael
9:00 Zwim Deposition at Susman's office (560 Lexington, 50'h & Lex, 151h
Floor)
June 15, Wednesday
8:30 Breakfast w/David Gelenter
10:00 Appt w/Doug Schoettle
11:00 Appt w/Rich Kahn, Emad Hanna and Bella Klein
1:00 Lunch w/Katherine Keating
June 16, Thursday
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assistant is Lisa Bauso,
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