DataSet-10
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92 pages
-4 Condensed Transcript
IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, FLORIDA
E.
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.
Jennifer DiLorenzo, court reporter
Toll Free:
Facsimile:
S Suite 1300
515 East Las Olas Boulevard
ESQUIRE • Al tas4trOblioCeropOn>
Fort Lauderdale, FL 33301
www.esquiresolutions.com
CONFIDENTIAL 3501.150-002
Page 1 of 92
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Larry Eugene Morrison - Volume I October 6, 2009
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• 211 TUR CIRCUIT COURT OP TER 15111 JWICJAL CIRCUIT IX
AMU FOR PALM SEAM COUNTY. FLORIDA
MAKE I Pages I to 200
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APPEARANCE OF COUNSEL
On WWI of the Defendant
ATTERBURY. GOLDBERGER a WEISS
BY: JACK MAN GOLDBERGER. ESO .
250 Ausbaban Avenue
Suite 1400
s . FL 33401
Plaintiff, 6
Case No. 502000C11024051
/0703111 AD On bead of the DeiceOwe by 1444410TIE:
JEFFREY EPS/811I.
BURMAN. CRITTON. LUTTER & COLEMAN
Defendant. 9 BY: MICHAEL J. PIKE. E90..
SIS N. Reeler Drive
10 Suite 400
IMPOSITION OP .F133101
LARRY Puma Pomace 11
TAKEN ON OEMAL7 Of THE PLAINTIFF
October 6. 2009 12
10,55 4.e. . 2:20 .n. 13
On behalf of the Aeneas:
14
LAW OFFICE OF BRUCE E. REINHART
IS BY: BRUCE E. REINHART, ESO..
One Gavle» Center
16 250 S. AUSIrtien Avenue
Suite 1400
Jennifer Ditonne°. court reporter 17 acn, FL 33401
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A
On beret dew Plante
I40114STEIN. feet
BY: BRADLEY J. EDWARDS LSO
and MICHAEL HEELER. ESO .
401 East Las am Elooleverd
COUNSEL
OT 6 ADLER
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WITNESS:
INDEX OF EXAMINATION
LARRY EUGENE MORRISON
Page
Sum IMO 6 DIRECT EXAMINATION
B. FL 33394
By Mr. Edwards *5
7
CROSS-EXAMINATION
a *190
On WW1 cpt Mew% a By Ms. Ezell
9 9 CROSS-EXAMINATION
MERUELSTEIN 6 HOSIOVATZ. By Mr. Wilds 0195
10 BY: JESSICA D. ARBOUR. ATTORNEYAT.LAW, 10
18205 Biscayne Boulevere CROSS-EXAMINATION
11 See 2216
11 By Mr. Pike *196
12 FURTHER REDIRECT EXAMINATION
By Mr. Edwards 8199
13
14 On bete d 13
ef 14
leNecee:
15
POOHURST ORSECK PA 15
14 BY: KATHERNE.A. &ELL ATTORNEY-AT.LAW.
25W. Page« Seem 16 INDEX TO EXHIBITS
1 17
Ptautfts
19 18 E.101bIt Description Page
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On Whaled tpe by IMPIzewle 19 1 Twenty-four pages of 'LIEGE. Inc..
20 Passenger Manifest' ii198
LAW OFFICE OF ROMP) WIWTS. PA. 20
21 BY: IIICHANDWLUTS. ESC.. 21
2290 ICIP•Avenue H.
21 se. 404 22
33631 21
24 (Plaintiff's Composite 1 was attached to flic
24 original transcript and codes of the transcript.)
25 25
• Toll Free:
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www.esquIresolutIons.corn
3501.150-002
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Larry Eugene Morrison - Volume I October 6, 2009
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Deposition of LARRY EUGENE MORRISON
October 6, 2009
THE REPORTER: Do you swear the testimony
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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
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5 you're about to give will be the truth, the 5 don't believe ft to be a money making company or a
6 whole truth. and nothing but the truth so help 6 real corporation.
7 you God? 7 O. You're saying 'for the aircraft.* I'm
THE WITNESS: So help me God. 8 interpreting that to mean you're talking about one
9 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. Ho owns more than one, but
14 BY MR. EDWARDS: 14 just one is JEGE or --
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 ancifor ride on?
17 O. And. Larry. where aro you employed right now? 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 lust do paperwork - and it was February of
20 A. Its the aviation flight department for 20 2007. So I haven't actualy physically been on the
21 Mr. Epstein. and my primary job * Dankjold Reed 21 airplanes other than I will lake the Boeing for
22 Aviation. 22 maintenance.
23 MR. REINHART: Spell A 23 O. Since it seems like we've kind of skipped
24 A. D-A-N-KJ-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
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department.
O. What do you dote him?
A. Director of Maintenance.
O. Okay, so you maintain his planes .-
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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
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5 A. Correct. 5 associate of my previous boss.
6 O. should something go wrong? 6 Q. Who's that?
7 A. Correct. Yes. Yep. 7 A. Mr. Wexner.
O. Do you also -- 8 O. Leslie Wexner?
9 A. For maintenance. 9 A. Yes.
10 O. Do you also fly on his planes? 10 O. How do you know Leslie Wexner?
11 A. On Mr. Epstein's? 11 A. I woiked for Limited Stores for 12 years.
12 a 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 Q. How many aircraft did Leslie Wexner have?
17 A. Yes. Yeah, it's just initials. It's an 17 A. Well none that I know that he had
18 ISC or heeding 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 taw? 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. On, no, no, somewhere -- It wasn't mine. 25 A. It was just It was called Limited -
0
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Fort Lauderdale, FL 33301
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3501.150-002
CONFIDENTIAL Page 4 of 92
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Larry Eugene Morrison - Volume I October 6, 2009
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Limited Flight Department.
O. And do you know him personally then - Leslie
Wexner?
A. Yeah. I had met him. of course, you know.
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O. Yes.
A. Aircraft technician.
O. Which entails what?
A. Maintenance of any or all of the aircraft
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 Leslie Wexner? O. What kind or airplanes?
A. 1988 was when I hired on, so I don't A. Gulfstreams, Hawkers.
9 remember the month. 9 O. How big is the Gulfstrearn?
10 O. How did you gel that fob? 10 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 Gullstream for?
14 O. Well, I mean. Leslie Wexners an important 14 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 tam. II 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 personally own it. Its 24 stores, or whatever, throughout all their divisions.
25 a publicly held company. 25 I mean, when you say *Limited.' its not
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O. Where were you prior to any involvement with
Leslie Wexner?
A. I worked for Red Roof Inn True Sports
Flight Department.
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just Limited, its Victoria's Secret and it was
Express and Lemers and Henn Bendel's and all of
that back then. so. I mean --
O. So -
5 O. How did that position lead you to Leslie s A. we moved a lot of passengers to keep
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 clie-is
8 Flight Department was one of the best jobs in of his?
Columbus and, actually, several other people that 9 A. That I don't know. No. Mostly we lust
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 fine organization. 14 A. Can't even remember names, but it would be
15 O. So did Mr. Wexner approach you or did you 15 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 w0ukInt 21 O. While you were working back in BI3- Well,
22 O. So you start with Wexner in 1988. 22 how long overall did you work with Leslie Wexner and/or
23 A. Yes. 21 his companies?
24 O. What do you do for him then? 24 A. Well, '88 through when I came hero in
25 A. What ced I do for him? 25 January of '01.
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CONFIDENTIAL 3501.150-002
Page 5 of 92
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Larry Eugene Morrison - Volume I October 6, 2009
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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 a takes to keep a
corporate flight department operating.
O. Did you know back then of his relationship. it
any. with Jeffrey Epstein?
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5 airplane three-pilot airplane - and it gave me the k Not immediately. no.
6 opportunity to become a Director of Maintenance. and 6 O. When is the first time that you know of a
7 it was a challenge. You know, bringing upstarting 7 reputation or a relationship between Wexner and Epstein'
8 an airliner on a private ticket or a VIP ticket is e A. Would have had to probably be around maybe
9 really challenging, and I enjoy the challenge of 9 '98,'99.
10 world% arid developing the program and stud. 10 O. How do you become aware that they know ono
11 O. Well, my understanding. Leslie Wexner Is 11 another?
12 generally - he's in Ohio. tight? 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 ckd 4 come about that he would nde on
17 would that be in Ohio -- 17 Wexners Boeing?
18 A. Yes. We were based -- le 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 retationsh-p
23 before you answer. 23 between the two?
24 THE WITNESS: Okay. I'm sorry. 21 A. Web, I believe it's pubic 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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Wexnees funds.
O. Is that something that Mr. Wexner told you?
A. No.
O. Is that something that somebody of Mr.
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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
8 A. Yes. yes. a 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 to' 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 ifs common
16 O. II I ask a question that was a bad question or 16 knowledge --
17 something you don't understand ive asked bad questions 17 A. Right.
18 before • say. 'I don't get it' I'll ask a better 18 O. But irs only because of what I've road. 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 Leslie 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 persona
23 what would you be doing? 23 relationship, if any, between Wexner and Epstein'
21 A. Maintenance, aircraft maintenance, 24 MR. GOLDBERGER: Form.
25 tracking of aircraft maintenance. cleaning of 25 A. Don't know.
0
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Larry Eugene Morrison - Volume I October 6, 2009
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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 lot me back up.
Have you ever stayed at Leslie Wexner's house?
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O. Have you spoken personally with Mr. Wexner?
A. On bus:Mess issues, yes.
O. Business Issues related to your work on his
airplanes?
A. No. 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 Q. Do you know what the address is in Ohio? e airplanes?
9 A. ND. I just know the City. 9 A. No.
10 O. Do you know who he lives with? 10 O. Because you're hired 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. en
14 O. What's his wile's namo? 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 don't, do you knOw any of
17 daughters. ngM? 17 his personal friends people that he would hang out with
18 A. No. He's got a son. and two l8 on a social level - being Mr. Wexner?
M
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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 hying to remember - You have to
22 I don't know what they have - it they have more kids 22 remember its been several years.
23 now. 23 O. Right.
24 O. Okay. Did you ever hew any information that 24 A. He was friends with the Tuckermans.
25 he was homosexual? 25 O. What's Mr. Tuckerman or Ms. Tuckennan's names?
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A. No.
O. Being Mr. Wexner.
A. No.
O. My Indication to you that he may be
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A. Ms. - I cant. 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? s They were high school friends from Mr. Wieners high
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? 8 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 Mars only because you know him and you 1
12 Epstein?
13 know Mr. Wexner and you don't see the two together. 3 MR. GOLDBERGER: Form.
14 A. Correct. 14 A. I don't understand. Can you rephrase il?
15 MR. GOLDBERGER: Form. 15 O. Wet you know that at some point in time
16 A. Weil — 16 You started working with him in 1988. The first time.
17 17 according to my notes. that you became aware Mat he was
18 A. Go ahead. 18 friends or acquaintances with Mr. Epstein was V8 -
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 Mere 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 Mat I would even conceive that. 25 O. So as far as you were concerned. 1998. when
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Larry Eugene Morrison - Volume I October 6, 2009
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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. Tim Staley. Jim Taylor. They've had some
tumover too. I don't know who all is still there
because retail is down.
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5 of Mr. Wexner's aircraft back in the '80s and. I guess. 5 O. Was Larry Visoski a pilot used by Leslie
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. 8 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 are 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 he 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 CAM? 16 Well, tell me if I'm wrong: I understand that you did
17 A. No, I can't 17 some work for Mr. Wexner related to his aircraft and you
18 O. If I requested that from your attorney, would 18 did some work for Mr. Epstein. which we haven't yet got
19 you be able to got 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 pathos?
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. 20 years ago - how often was Mr.
Wexner personally al that location at the Limited
offices?
A. I have no idea.
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O. One of them. Then you also have knowledge
about Mi. Epstein and some relationship with Mr. Epstein.
A. Correct.
O. Are there any other pilots. aircraft
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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 7 A. No. no.
8 Hinson. 8 O. Do you knew 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 10 O. How long - if you started in 1988 how long
11 basically was my go-between for these aircraft 11 did you slay with Mr. Wexner and/or The Limited?
12 completions for the design. 12 A. January of YR.
13 O. And you mentioned the Gullstream as an 13 O. Why did you stop?
14 aircraft Did you also serve as a tech
DataSet-10
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2 pages
Case 9:08-cv-80119-KAM Document 15 Entered on FLSD Docket 06/3012008 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT'S NOTICE OF FILING DEPOSITION
In support of his motion to stay this action [DE 12], defendant Jeffrey Epstein hereby
files the redacted deposition of Jane Doe #1 (Case No. 08-80069-Civ-Marra/Johnson), taken in
State of Florida Jeffrey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit,
Palm Beach County). The redacted deposition is attached hereto as Exhibit A.
Respectfully submitted,
ATTERBURY, GOLDBERGER & WEISS, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, Florida 33401
Tel: 561 659 8300
Fax: 561 835 8691
By: /s/ Jack A. Goldberger
Jack A. Goldberger
Fla. Bar No. 262013
[email protected]
Attorneys for Defendant Jeffrey Epstein
EFTA00222289
Case 9:08-cv-80119-KAM Document 15 Entered on FLSD Docket 06/30/2008 Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 30, 2008, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
is being served this day on all counsel of record identified on the following service list via
transmission of Notices of Electronic Filing generated by CM/ECF.
Jeffrey M. Herman, Esq.
Herman & Mermelstein, P.A.
18205 Biscayne Blvd, Suite 2218
Miami, Florida 33160
via CM/ECF Notice ofElectronic Filing
/s/ Jack A. Goldberger
Jack A. Goldberger
2
EFTA00222290
DataSet-10
Unknown
1 pages
From: Darren Indyke
To: "Jeffrey E."
Subject: Privileged and Confidential
Date: Thu, 05 May 2016 15:41:27 +0000
Attachments: Dershowitz Deposition.pdf
EFTA01182333
DataSet-10
Unknown
1 pages
To: jeevacation©gmail.com[jeevacation©gmail.com];
jeevacationegmail.com[jeevacation©gmail.com]
From: Gmax
Sent Fri 3/18/2011 1:10:06 PM
Can I have VR deposition please ASAP
Thx
EFTA_R1_00512560
EFTA02011089
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46 pages
Page 50:
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
Plaintiff,
-vs- VOLUME IV OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
Tuesday, February 09, 2010
10:09 - 5:05 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1296
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by cynthia hopkins (0014151-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934) b55421ef-d299-4e4f-9ba6-85and27f4405
EFTA01108851
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Page 503 Page 505
1 APPEARANCES: 1 PROCEEDINGS
2 On behalf of the Plaintiff. and Jane
3 BRAD J. EDWARDS.
DDe .
2
FARMER, JAFFE, WE/SSING, EDWARDS 3 THE VIDEOGRAPHER: We're back on the
I,PJ02MAt4. PL
record at 1:48 p.m.
5 BY MR. LUTHER:
6 Q. Okay, Ma'am. I want to add that during
7 On behalf o the Jeffrey Epstein: 7 the morning session, I was asking you some
3 ROBERT D. CRITTON,11t, P8QUIRE 8 questions. I just want to go over a couple of
MARK T. tura ESQUIRE
9 R • wt ft* LLITTIER & COLEMAN, ELP 9 things. One of the first things I asked you this
10 morning is whether you understood you were under
11 oath today. And you indicated you did understand
12 that?
12 On o the a r: ant, ;army Epstein: 13 A. Correct.
13 JACK ALAN GOLDBERGER. ESQUIRE
• R & WEISS, PA. 14 Q. Are you, did you, are you aware of the
14 15 fact that it is a crime known as perjury to make a
16 false statement under oath?
17 A. Correct.
16 18 Q. Are you also aware that it is a separate
17
18 ALSO PRESENT. kffrey Epstein, via video conference 19 crime, a federal crime to make a false statement to
4/”.ney, Videogmpber
Daniel C1 20 an FBI agent?
19 Visual Evidence, Incorporated 21 A. Correct.
20
21 22 Q. And you've already admitted that you
22 23 committed that federal crime; you lied to the FBI,
23
24 24 according to you.
25 25 A. I was in fear of my sorts life, correct.
Page 504 Page 506
1 1 Q. Now, l want to ask you one more time: Is
2 INDEX VOLUME I 2 there anything you want to correct about any of your
3
3 testimony this morning, especially as it relates to
4
5 "NESS: DIRECT CROSS REDIRECT RECROSS 4 working in places of employment that you have termed
5 5 to be jack shacks at or about or near Speannim
7 6 Rhino?
BY MR. LUTHER 4 7 A. Correct. I'm fine on that
8 8
9
Q. Okay. Isn't it a fact that on Saturday,
10 9 January 30th, you went to Spearmint Rhino's?
11 EXHIBITS 10 A. Yes.
12 11 Q. And you got there, what time, around 8:00?
13 2 A. Yes.
14 EXHIBIT DESCRIPTION PAGE
15 DEFENDANT'S NO.3
13 Q. And then at some point in time you la
Photo of Fantasies of Palm Beach 512 14 Spearmint Rhino's, did you not?
16 15 A. Yes.
DEFENDANTS NO. 4 518 16 Q. And you went to a place called Fantasies
17 Photo of Demon's Motorcycle ad 17 of Palm Beach, did you not?
18 DEFENDANTS NO. 5 634
•' unction for
18 A. Not that I recall. I don't know a name
19 19 Fantasies.
20 DEFENDANTS NO. 6 618 20 Q. Well, Fantasies of Palm Beach would be the
tinctice for 21 facility that's located right next door to Spearmint
21 22 Rhino's. You're familiar with that, aren't you?
22
23 23 A. I thought that was affiliated with Spearmint
24 24 Rhino.
25 25 Q. Well, so that we 'mow -
2 (Pages 503 to 506)
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EFTA01108853
Page 507 Page 509
1 (Cellphone interngtion.) 1 located, I believe it's to the left side of
2 THE WITNESS: Oh, Pm sorry, my phone. 2 Spearmint Rhino's as you look at it. It's got a
3 MR. Lill-TIER: Sure. Oo ahead. 3 separate entrance. It's got neon signs on it?
4 THE WITNESS: Okay. Sorry. 4 A. Okay.
5 BY MR. LUTHER: 5 Q. And it's known as Fantasies of Palm Beach.
6 Q. There is a — whether or not ifs 6 You're aware of that place, aren't you?
7 affiliated with Spearmint Rhino, I don't know. When 7 MR. EDWARDS: Fan
8 you referred to your testimony this morning that you 8 THE WITNESS: I'm not aware of any name.
9 didn't go anyplace other than Spearmint Rhinos and 9 BY MR. LUTTIER:
10 places affiliated did, with it, did you mean to 10 Q. Well, you were in the establishment known
11 include in those places that you went Fantasies of 11 as Fantasies of Palm Beach on the evening of
12 Palm Beach? 12 Saturday, January 30th, 2010, were you not?
13 A. I personally never heard of Fantasies of Palm 13 MR. EDWARDS: Font.
14 Beach, but I know that, there, that Spearmint Rhino has 14 THE WITNESS: If that's what it's called,
15 a couple places affiliated with them. 15 then, yes. But, as long, as far as I know,
16 Q. What places do they have that are 16 Spearmint Rhino, that's the name I know it as
17 affiliated with them? 17 you know.
18 A. The back and then there's an entrance to 18 BY MR. LUTTIER:
19 another place. That's all ! know. 19 Q. Well, this is a place that has a separate
20 Q. Well, tell me about this entrance to 20 entrance. You don't go through the entrance of
21 another place. What are you talking about? 21 Spearmint Rhino. You go into a separate entrance
22 A. Well, in the back of Spearmint Rhino there is 22 for a place called Fantasies of Palm Beach.
23 a little section that the dancers I don't know 23 A. Well -
24 exactly what they do there, but that's where I do sell 24 Q. I want to make sure we're real clear here
25 shoes and my lingerie. 25 we're not playing semantics.
Page 508 Page 510
1 And then there is another entrance that 1 A. We're not playing what?
2 you can go through and then there is another it's 2 Q. Semantics.
3 like there's, I know that there's, there's a lot of 3 A. Okay.
4 doors. I don't know what they consist of. 1 don't 4 MR. CRITTON: Word games.
know what they do there, but I know that they are 5 THE WITNESS: Oh.
6 affiliated, I thought that they were affiliated with 6 MR. LUTTIER: All right?
7 Spearmint Rhino, and that's where I also go to sell 7 THE WITNESS: Yeah.
8 my shoes and ptuses. 8 BY MR. LUTTIER:
9 Q. Okay. Well, you talked about a place in 9 Q. And, and you were, in fact, in this place
10 the back of Spearmint Rhino's that you gain access 10 called Fantasies of Palm Beach on Saturday, January
11 to by going through the Spearmint Rhino 11 30th, 2010, were you not?
12 establishment? 12 MR. EDWARDS: Object to the form.
13 A. Yes. 13 THE WITNESS: I definitely walked through
14 Q. All right. Now, what is this second place 14 an entrance and that I thought was affiliated
15 that you are talking about that you say is 15 with Spearmint Rhino.
16 affiliated with Spearmint Rhino's? 16 BY MR. LUTTIER:
17 A. Well, you can either go through out the back 17 Q. And there's a black female in there that
18 door of Spearmint Rhino and take a right, and then there 18 works at the front desk, is there not? There was on
19 is a place there that's affiliated with them. 19 Saturday night.
20 Q. Is there a name? Is there a separate 20 A. Oh, I don't know. I don't know who works
21 entrance to the place? 21 there. I don't blow.
22 A. 1— they're connected. 22 Q. And the --
23 Q. Is there a separate name on this place? 23 A. I just know that I go into Speannint Rhino and
24 A. Not that I know of 24 I sell my —
25 Q. Okay. I'm tallthsabout a place that's 25 Q. And —
4,1 J
3 (Pages 507 to 510)
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EFTA01108854
Page 511. Page 513
— items. 1 A. No. I say to the girls, my name is Lynn and
2 the name that you're known as is 2 they know that I sell all of my, all of my clothes and
3 isn't that right? 3 lingerie and shoes and everything else I sell.
4 A- I'm not known as 4 Q. But there is no doubt that now that you
5 Q. That's the name you -- remember we were 5 have seen this picture, you were in that
6 asking you about the cards you used to use? 6 establishment that is depicted on Exhibit No. 3 on
A. Yeah, I was known as =in '07 and '08. 7 January 30th, right?
8 O. that's the name you've used in the past 8 A. Correct.
9 is 9 Q. And you drive a white Mitsubishi Gallant;
10 A. Yes. 10 is that right?
11 Q. And in fact on Saturday, January 30th, you 11 A. Yes.
12 were working in Fantasies of Palm Beach which was. i2 Q. License plate number is 193HV; is that
13 to use your terms, a jack shack, were you not? 13 correct.
14 A. No, I was not working there. 14 A. I don't know my license plate number, but 1
15 Q. And you were charging $120 fora half hour 15 definitely drive a white Mitsubishi Gallant
16 to perform services; isn't that right? 16 Q. And is, was that vehicle parked outside
17 A. No. 17 Fantasies of the Palm Beach on Saturday night,
18 Q. Andacame out and told somebody your 18 January the 30th?
19 name was Mend that that was your charge, 19 A. Yes, but like I said before, from my
20 didn't you not? 20 knowledge, I thought this was affiliated with Spearmint
21 A. No, I did not. All I do is sell shoes and 21 Rhino.
22 purses there. 22 Q. And that car --
23 MR. LUTRER: Let me show you a picture 23 A. And they don't like me to park, they don't
24 here which we'll mark as, !guess we want to do 24 like me to park in front of Spearmint Rhino because
25 it in order. It will be Exhibit 3. 25 there are so many clientele that goes in and out. So
Page 512 Page 514
1 (Defendant's Exhibit No. 3 was marked for 1 they need as much parking space as they can.
2 identification.) 2 Q. And you stayed at Fantasies of Palm Beach
3 THE WITNESS: This place, yeah, ifs next 3 until what hour on the morning of Sunday which would
4 to Spearmint Rhino's. 4 be January 31st?
5 MR. LUTTTER: Hold on. Hold on. 5 A. I stayed until what time?
6 TI WITNESS: Sorry. 6 Q. Yeah, the morning until — what time on
7 BY MR. LUITLER: 7 the morning of Sunday, January 31st, did you leave?
8 Q. I have to ask you a couple of questions. 8 A. Well, Spearmint Rhino, I would go until
9 Do you recognize Exhibit 3? 9 closing like 5, 6. And then in the back of here, of
10 A. Yes, but what I would do, I would go out of 10 Spearmint Rhino, that's like, sometimes they have after
11 Spearmint Rhino from the back and go into the back 11 pa-ties there, something. This is what I hear from the,
12 entrance of Fantasies or whatever this place is called. 12 the manager at Spearmint Rhino. And like I said,
13 Q. So so, now upon seeing the picture, you 13 sometimes I stay there and I have a couple of drinks.
14 want to correct your testimony and say, in fact, you 14 And I'm not sure what time I left.
15 were in Fantasies of Palm Beach on Saturday? 15 Q. I don't want to know —
16 A. I, from my understanding, from my knowledge, I 16 A. As long as I keep on selling shoes and
17 thought that this place was owned by Spearmint Rhino. 17 lingerie, I'm the there.
18 Q. All right. The place of business that's 18 Q. I am not asking about sometimes. h am
19 depicted in Exhibit No.3, were you in that place of 19 talking about Sunday morning, January 31st, 2010,
20 business on Saturday, January 30th? 20 what time did you leave on that day?
21 A. Yes, selling my items. 21 A. I couldn't tell you that. 1 don't know.
22 Q. And did you, in fact, on that night, on 22 Q. Well, what's your best estimate?
23 Saturday, It 30th, tell individuals that your 23 A. I don't know, sir.
24 name was and that you charged $120 per half 24 Q. Well, first of all you closed Spearmint
25 hour? 25 Rhino at, what 5 in the morning?
4 (Pages 511 to 514)
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Page 515 Page 517
1 A. I closed it? 1 A. And we started talking to people.
2 Q. Yeah, you were them until it closed? 2 Q. Who did you talk to in particular?
3 A. Yes. 3 A. I don't know anyone else.
4 Q. And then you went over to Fantasies, 4 Q. Did you talk to a male there?
5 right? 5 A. Yeah.
6 A. That I thought was Spearmint Rhino from the 6 Q. Have him over at your table?
7 back 7 A. He came closer to — we were at the bar.
8 Q. Whatever. 8 Q. The three of you were talking, were you
9 A. Okay. 9 not?
10 Q. And then, how much longer did you stay 10 A. Yeah.
11 there? 11. Q. Do you remember the guy having a laptop?
12 A. I stayed there a little while because there is 12 A. Yes.
13 more girls there that like to buy my items. 13 Q. What did you-all do on the laptop or what
14 Q. Now, let's talk about your trip to New 14 did he do on the laptop while you were there and you
15 York 15 both were sitting there?
16 A. Okay. 16 A. Well, I told him that I modeled for Demons
17 Q. Tuesday, February 2nd, 2010. Remember 1 17 Cycles. And I told him if he would like to see my
18 asked you earlier about whether you ever used any 18 pictures, to go onto Demons Cycles.
19 business cards? 19 Q. So, did you tell him about any other
20 A. Yes. 20 websites?
21 Q. When you went on this trip to New York, 21 A. Excuse me?
22 did you have any cards? 22 Q. Did you tell him about any other websites?
23 A. No, not that I no. 23 A. No, not that I recall.
24 Q. Did have any cards? 24 MR.LIMIER: Let's mark this as
M.
25 A. Not that I know of. 25 exhibit — what's this, 4?
Page 516 Page 518
1 Q. Did you, when you went to the Palm Beach 1 THE COURT REPORTER: Four.
2 International Airport, did you give the taxicab 2 MR. urrIIER: Mark this as 4.
3 driver a card? 3 MR. EDWARDS: Is Exhibit 1 and 2 marked -
4 A. Did I give hi card? 4 MR. LUTTIER: Yeah.
5 Q. Yeah, you or ., little business card? 5 MR. EDWARDS: in the previous depo?
6 A. I didiagive him a card, no. 6 MR. LUFTIER: Yeah, the previous depo.
7 Q. Did M. give him a business sand? 7 Although I don't know where the exhibits are or
8 A. Not that I know of. • 8 they went.
9 Q. When you went into the Palm Beach 9 MR. EDWARDS: Okay.
10 International Airport, your card — do you recall 10 MR. LUTT1ER: It was like answers to
11 going to a bar? 11 interrogatories. Something like that.
12 A. Palm Beach International Airport, yeah, I went 12 MR. EDWARDS: Okay.
13 to a bar there — 13 (Defendants Exhibit No. 4 was marked for
14 Q. What bar do you go to? 14 identification.)
15 A. — because I totally missed the flight. 15 BY MR.
1.6 Q. What bar did you go to? 16 Q. Let me show you what's been marked as
17 A. I think it was Fridays, if I am not mistaken 17 Exhibit 4 and ask you if you can identify that.
18 or not. I don't know what it was called. 18 A. This is —
19 Q. Who went tuk bar with you? 19 MR. EDWARDS: Wait until he asks you a
20 A. 1 went with M. to the bar and it was just 20 question.
21 her and 1. 21 BY MR. LUTHER:
22 Q. And for how long was it just the two of 22 Q. Can you identify it?
23 you? 23 A. Yes.
24 A. For like ten minutes. 24 Q. What is it?
25 Q. And then what happened? 25 A. This is --1 modeled for Demon Cycles and it
5 (Pages 515 to 518)
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Page 519 Page 521
1 is their advertisement now. 1 Q. Did you do anything else that evening?
2 Q. And is this one of the pictures on your 2 A. Yes, we went out to dinner.
3 website? 3 Q. After you — did you leave the apartment
4 A. On my website? 4 and go look around at Grand Central Station and then
5 Q. Yeah, or your Facebook, I guess, account 5 keep on walking around or did you come back to the
6 or MySpace, whatever it was. 6 apartment?
7 A. Yeah, I have posted it on there, yeah. 7 A. We went back to the apartment.
8 Q. Is, was this one of the pictures you were 8 Q. Okay. And then there came a time after
9 telling us at your last deposition that you really 9 you came back from sightseeing that you left the
10 wouldn't want your four-year-old son to see? 10 apartment a second time?
11 A. No, that's fine if he sees this. This is, 11 A. Yes
12 this is very legit. His mother modeled and I am 12 Q. And that was for what purpose?
13 actually very proud of this photo. 13 A. We went to Angelo's.
14 Q. All right. Now, did you do anything else 14 Q. Okay. And how did you get to Angelo's?
15 with this inditinial before you left the bar that 15 A. We got to Angelo's in a trod.
16 you, you and M. were tenting to at the Palm Beach 16 Q. Alexi?
17 International Airport? 17 A. Uh-huh.
18 A. Did we do anything with him? 18 Q. And that was about what time?
19 Did you give him anything, either you or 19 A. Oh, jeez, maybe, maybe 9:00.
20 20 Q. Between the time — what time did you go
21 A. I don't recall givingain anything but — 21 looking at Grand Central Station?
22 Q. Well, did you see M. give him anything? 22 A. That was before 9:00.
23 A. No. 23 Q. Okay. And do you remember, do you recall
24 Q. Did either one of you give him a business 24 that evening an individual by name of Martin
25 card? 25 Krouner?
Page 520 Page 522
1 A. I don't have any business cards. I don't — 1 A. Do I know a man named Martin?
2 Q. Well, I don't — you may want to be 2 Q. Uh.huh, Martin Krouner.
3 careful here. I don't want to trick you. lam not 3 A. No.
4 playing semantics. Did either you or give him 4 Q. Do you remember getting in a black
5 a business card? 5 Series 5 BMW when you came out of the condominium?
6 MR. EDWARDS: Object to the form. 6 A. We, we did take a ride with a man.
7 THE WITNESS: Not that I recall, no, sir. 7 Q. Well, 'thought you just told me you
8 We had a few drinks and, and we were off to our 8 walked to the restaurant.
9 flight. 9 A. No, 'told you I took a cab to the restaurant.
10 BY MR. LUTTIER: 10 Q. Oh, took a cab to the restaurant?
11 Q. And then you flew to New York and you took 11 A. Yes.
12 a c and u went to this apartment that's located 12 Q. Did you forget about getting in a car with
13 at 'n New York: is that ri t? That 13 this man?
14 would be the corner o anc Street? 14 A. He took us a little sightseeing. No, I did
15 A. rings a bell. 15 not forget about that.
16 That's where we stayed? 16 Q. Was that before dinner?
17. Q. Yeah. 17 A. That was before dinner, yes.
18 A. Yeah. 18 Q. Did you just fail to mention that or —
19 Q. Now, on that evening, the first night that 19 this is different than the man who took you
20 you got there on Tuesday, I think earlier you said 20 sightseeing later, isn't it?
21 you-all walked down a street and went to dinner, is 21 A. Yes.
22 that right? 22 Q. Okay. So, tell me who Martin Krouner is.
23 A. We walked down the street and we walked into 23 A. I don't know his name, if that is his name.
24 a, I think it's Grand Central Station. I'm not sure 24 Q. Well, the guy that picked up in the black
25 because I'm not from there and we looked around. Yeah. 25 BMW, who's he?
6 (Pages 519 to 522)
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Page 523 Page 525
1 A. I guess a friend of Anna's. 1 fellow here, Mr. Martin Krouner?
2 Q. Well, tell us how old this individual was. 2 A. If that's his name. I don't know if we took a
3 Describe him for us. 3 picture of him, but we definitely took pictures of..
4 A. He has not a lot of hair. He's about five-six 4 and I.
5 maybe and a little chubby. 5 Q. And, and where did you take those
6 Q. For what purpose were you — and you never 6 pictures?
7 met him before? 7 A. Wherever we were.
8 A. No. 8• Q. Okay. And when this man brought you back,
9 Q. In never met him before? 9 did he go to dinner with you? •
10 A. No. 10 A. He ended up meeting us there, yes.
11 Q. You didn't have any idea who he was? 11 Q. Did he drop you at the restaurant?
12 A. No. 12 A. He dropped us near so we can get there with a
13 Q. You-all climbed in his car? 13 taxi. He dropped us somewhere off of the street and we
14 A. Yeah, I think it was Anna's friend. 14 went with a taxi.
15 Q. Okay. What did Anna tell you about the 15 Q. So, he dropped you off and then you got a
16 guy? 16 taxi to get there?
17 A. She's Chinese. She's like go, go; go, go have 17 A. To go to Angelo's, yeah.
18 fun, go search the town. 18 Q. And then he met you there later?
19 Q. So, where did you go with Martin? 19 A. Lateran.
20 A. We ended up meeting him at Angelo's. 20 Q. Okay. About what time?
21 Q. Wait a minute. You got — first of all 21 A. Oh, God, I don't know the times. Maybe this
22 you got in Martin's car, right? 22 was around, maybe around — I'm — this is total
23 A. I got into Martin's car, yes. 23 ballpark, Mee 10 maybe.
24 Q. And then where did you go once you got in 24 Q. Okay. An d, and then after dinner
25 Martin's car? 25 what did you and M. and he do?
Page 524 Page 526
1 A. We searched around the town. 1 A. Well, we took a taxi back to his car. And we
2 Q. What do you mean you searched around? 2 went up to the, we went up to Anna's room and he just --
3 A. We went sightseeing. 3 we just said bye.
4 Q. Okay. Do you remember where you went? 4 Q. And did you receive anything at all of
5 A. And we went sightseeing. 5 value from this man?
6 Q. Do you remember where you want 6 A. No.
7 sightseeing? 7 Q. Did you charge him anything?
8 A. Then we took a taxi. No, because I don't know 8 A. No.
9 the area. 9 Q. Were you paid anything for the time you
10 Q. You went sightseeing in Mr. Kroner's car, 10 spent with him?
11 correct? 11 A. No.
12 A. Yes. 12 Q. Now, who's Robert Fredrick Burke?
13 Q. All right. And, and did there come a time 13 A. Robert Fredrick Burke, I have no idea.
14 that you got of Mr. Kroner'S car? 14 Q. Well, on the next day on Wednesday,
15 A. Yeah, and we looked around. It was finning 15 February 3rd, did you go sightseeing again?
16 outside, so it was nice to feel the snow. 16 A. Yes, we did.
17 Q. And where did you get out of the car? 17 Q. And you said that this fellow Bobby came
18 A. Sir, I don't know New York. I don't — 18 to see you at the apartment sometime the morning of.
19 Q. Well, was it at a restaurant? Was it at 19 Wednesday, February 3rd?
20 the pool? Was it back at the condo? Where was it? 20 A. He came to see us, uh4tuh. Pm not sure what
21 A. it was near a whole bunch of buildings. 21 time it was. I think it was around in the afternoon.
22 Q. By the way, did you take any pictures 22 . Okay. And then after he kit, you and
23 while you were up there? 23 did some more sightseeing?
24 A. I did take pictures. 24 A. Yeah, we walked around town.
25 a Take a picture of you and ■ and this 25 Q. Do you remember getting in a vehicle with
7 (Pages 523 to 526)
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Page 527 Page 529
1 somebody that night? 1 A. I have no idea.
2 A. Yes. 2 Q. Were they a male's clothes or female's
3 Q. Who did you get in a vehicle with? 3 clothes?
4 A. I told you, I don't know his name. 4 A. I didn't search through the garbage. I just
5 Q. Well, where did you, where did you meet 5 know that I threw out the trash.
6 this person? 6 Q. So you're telling me you don't know whose
7 A. Everybody was Alma's friend. Anna has a lot 7 they were?
3 of friends. 8 A. No.
9 Q. Well, what did you know about the person? 9 Q. Okay. Do you know
10 A. Nothing. 10 A. Yes, Id°.
11 Q. How old is the person? 11 Q. And how do you know
12 A. I told you, I don't know anything about him. 12 A. We grew up together. Firerably 'mew her since
13 Q. And what kind of vehicle did you get in? 13 1was 12.
14 A. I don't even know the vehicle. 14 Q. Have you ever been engaged in any kind of
15 Q. Toyota Highlander? 15 a business venture, regardless of whether it was a
16 A. (sit — I don't know. 16 formally formed business venture like a corporation,
17 Q. And what nationality is this individual? 17 but any kind of business venture with .M?
18 A. I have no idea. 18 A. I went, we went to Jeffrey's togWer.
19 Q. And where did this individual take you? 19 Q. My other kind of business venture, you
20 A. He took us to sightseeing and he took us to 20 and heft
21 the Statue ofLiberty, everywhere. 21 A. No.
22 Q. Did you receive anything of value from 22 Q. Were you ever, did you ever represent or
23 him? 23 attempt to start a business venture with her?
24 A. No. 24 A. This is years ago.
25 Q. Did you charge him anything? 25 Q. How many years ago?
Page 528 Page 530
1 A. No. 1 A. Well, 13, 14, 15, like eight years ago.
2 Q. You or El? 2 Q. Okay. So, this is 2010. We're talking
3 A. I did not charahim anything. 3 about 2002?
4 Q. How about ? 4 A. Yeah.
5 A. I don't know what she does but, no, I don't 5 Q. Okay. So tell us about the venture that
6 think so. 6 you were forming with her?
7 Well, was there ever a time that you and 7 A. I don't know what you're talking about.
8 were not together in this person's presence? 8 Q. Well, you were thinking about something
9 A. Other than me going to the restroom, no. We, 9 because you said years ago. You were the one that
10 I, we were pretty much together the whole time. 10 picked the date. So, what was it you were thinking
11 Q. On the evening ofFebruary 3rd, 2010, do 11 about?
12 you recall throwing a bag of trash in the garbage? 12 A. No, I said years ago we, we knew each other.
13 MR. EDWARDS: Mat date is that? 13 We used to hang out. Like we used to do little girl
14 MR. LUITIER: The evening of February 3rd, 14 stuff, go in the pool and —
15 2010, at approximately 9:00 p.m. 15 Q. No, my question was, was there a business
16 THE WITNESS: In the evening. 16 venture and you said it was years ago.
17 MR. LUTHER: Just before you got in the 17 A. It was years ago that I've known her. Any
18 Toyota Highlander. 18 type of business venture, not that I recall.
19 THE WITNESS: Yes, we did. 19 Q. Have you ever told anyone at all that you
20 BY MR. WITTER: 20 and were forming a business venture or had a
21 Q. Okay. And do you recall what it was that 21. business venture?
22 was in that bag? 22 A. At 12, no, I don't —
23 A. There was whole bunch of clothes and 23 Q. At any, I don't care, right up until
24 everything that Anna did not want, so we threw it out. 24 today.
25 Q. And whose clothes were those? 25 A. No. 9
8 (Pages 527 to 530)
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.' .(561) 832-7506
Electronically signed by cynthia hopkins (601-061-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (001-061.976.2934) b55421ef.d299-4e4f-9bat3-85aad2714405
EFTA01108859
Page 531 Page 533
1 Q. Did you ever have any sort of a business 1 Q. And you testified that she provided you
2 venture that involved in any way, shape, or form you 2 with drugs?
3 and/or her taking showers? 3 A. Yes.
4 A. No. 4 e Q. All right. Now, who provided the drugs to
5 Q. Did you ever tell anybody you did? 5
6 A. No. A. I have no clue.
7 Q. Did you ever have any literature or 7 Q. Well, who provided the drugs to you that
8 written material describing such a venture? 8 you just claim you took when you were with
9 A. Not that I recall, sir. 9 A. I couldn't even say. Maybe, maybe
10 Q. Ever have anything that described such a 10
11 venture or any costs associated with procuring those 11 Q. That's your boyfriend?
12 services if someone wanted to do that? 12 A. At the time he was my boyfriend.
13 A. Taking showers? 13 Q. Well, he was your boyfriend. He became
14 Q. Well, taking showers or watching the two 14 the father of your child, right?
15 ofyou take showers or any combination or 15 A. Yes.
16 permutation that you can think of. 16 Q. Okay. I mean, that would qualify as a
17 A. Not that I can think ofunless we were like 17 boyfriend, right?
18 stupid little girls who — I don't recall anything about 18 A. If that's what you call it
19 any shower or anything like that, no. 19 Q. He was a drug dealer, wasn't he?
20 Q. Did you ever tell anybody that you had 20 A. No.
21 such a business going? 23. MR. EDWARDS: Form.
22 A. No. 22 BY MR. LUTHER:
23 Q. Did you ever tell anybody you had such a 23 Q. Did he provide drugs to you on more than
24 business going with someone other than e? 24 one occasion?
25 A. A business going, no. 25 A. No, he, no, he, if anything, him and his
Page 532 Page 534
1 Q. I don't mean a formal thing, Did you ever 1 friends got together and they were stupid and young and
2 tell anybody that you were involved in any kind of 2 they did a couple of drugs, but I didn't want anything
3 activity involving taking showers for which you got 3 to do with them until I met Jeffrey. And then I wanted
4 paid money? 4 to numb myself to be around Jeffrey. And I know that I
5 A. Definitely not. I don't — I have never. 5 would take drugs fro
DataSet-10
Unknown
12 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Leslie Wexler on Friday, August 14, 2009, at 11:00 a.m., at:
McGinnis & Associates
5701 North High Street
Suite 300
Worthington, OH 43085
(614) 431.1344
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 al day of July, 2009 to all those on the
attached Service List.
1
EFTA00779722
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: bedwardserra-law.com
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: US Legal Support
Court Reporters
EFTA00779723
AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District of Florida
JANE DOE
Plaintiff
v. Civil Action No. 08-80893CIV-MARRNJOHNSO
JEFFREY EPSTEIN
(If the action is pending in another district, state where:
Defendant
SUBPOENA TO TESTIFY AT A DEPOSITION
OR TO PRODUCE DOCUMENTS IN A CIVIL. ACTION
To: Leslie H. Wexler, One Whitebam Road, New Albany, Ohio 43054
I Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate
one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf
about the following matters, or those set forth in an attachment:
Place: McGinnis & Associates Date and Time:
5701 North High Street, Suite 300 08114/2009 11:00 am
Worthington. OH 43085
The deposition will be recorded by this method:
O Production: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
material:
The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
attached.
Date: 2_
CLERK OF COURT
Signature of Clerk or Deputy Clerk Attorney's signature
The name, address, e-mail, and telephone number of the attorney representing (name ofparty)
, who issues or requests this subpoena, are:
Brad Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER ,
Attorneys for Plaintiff, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301, [email protected]
(?..5¢-,) 52_2_ s4-.5-6
EFTA00779724
AO SSA (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2)
Civil Action No. 08-80893CIV-MARRA/JOHNS0
PROOF OF SERVICE
(This section should not befiled with the court unless required by Fed. R. Civ. P. 45.)
This subpoena for (name of individual and title, Vary)
was received by me on (date)
O I personally served the subpoena on the individual at (Place)
on (date) ; or
O I left the subpoena at the individual's residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual's last known address; or
O I. served the subpoena
. . on (name of individual) , who is
designated by law to accept service of process on behalf of (name oforganization)
on (date) ; or
O I returned the subpoena unexecuted because ; or
O Other (specift):
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
My fees are $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc:
EFTA00779725
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Glenn Russell Dubin on Tuesday, August 18, 2009, at 11:00 a.m., at
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this 28 day of July, 2009 to all those on the
attached Service List.
EFTA00779726
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: bedwardsc&rra-law.com
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: US Legal Support
Court Reporters
EFTA00779727
AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District of Florida
JANE DOE
Plaintiff
v. Civil Action No. 08-80893CIV-MARRAJJOHNSO
JEFFREY EPSTEIN
(If the action is pending in another district, state where:
Defendant )
SUBPOENA TO TESTIFY AT A DEPOSITION
OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION
To: Glenn Russell Dubin, 1010 5th Avenue, Unit 10A, New York, NY 10028
Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
deposition to be taken in this civil action: If you are an organization that is not a party in this case, you must designate
one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf
about the following matters, or those set forth in an attachment:
Place: Esquire Court Reporters Date and Time:
One Penn Plaza, Suite 4715,New York, NY 10119 08/18/2009 11:00 am
The deposition will be recorded by this method:
0 Production: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
material:
The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
attached.
Date: 7/2107
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk Attorney's signature
The name, address, e-mail, and telephone number of the attorney representing (name oniony)
, who issues or requests this subpoena, are:
Brad Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER ,
Attorneys for Plaintiff, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301, [email protected]
(r≤q ) ≤2-z 341,s6
EFTA00779728
AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2)
Civil Action No. 08-80893CIV-MARRNJOHNSO
PROOF OF SERVICE
(This section should not befiled with the court unless required by Fed. R. Civ. P. 45.)
This subpoena for (name ofindividual and title. if any)
was received by me on (date)
O I personally served the subpoena on the individual at (place)
on (date) ; or
O I left the subpoena at the individual's residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual's last known address; or
O I served the subpoena on (name ofindividual) , who is
designated by law to accept service of process on behalf of (name oforganization)
on (date) ; Or
O I returned the subpoena unexecuted because ; or
O Other (specify):
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
My fees are $ for travel and $ for services, for a total of S 0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc:
EFTA00779729
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Ghislane Noelle Maxwell on Monday, August 17, 2009, at 11:00 a.m., at:
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this 23 day of July, 2009 to all those on the
attached Service List.
1
EFTA00779730
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: [email protected]
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: US Legal Support
Court Reporters
EFTA00779731
AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or Produce Documents in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District of Florida
JANE DOE
Plaintiff
v. Civil Action No. 08-80893CIV-MARRA/JOHNSO
JEFFREY EPSTEIN
(If the action is pending in another district, state where:
Defendant
SUBPOENA TO TESTIFY AT A DEPOSITION
OR TO PRODUCE DOCUMENTS IN A CIVIL, ACTION
To: GHISLANE NOELLE MAXWELL, 116 E. 65 LLC, NEW YORK
I Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate
one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf
about the following matters, or those set forth in an attachment:
Place: Esquire Court Reporters Date and Time:
One Penn Plaza, Suite 4715,New York, NY 10119 08/17/2009 11:00 am
The deposition will be recorded by this method:
0 Production: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
material:
The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
attached.
Date: 7/2 7/0 9
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk Attorney's signature
The name, address, e-mail, and telephone number of the attorney representing (name ofparty)
, who issues or requests this subpoena, are:
Brad Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER ,
Attorneys for Plaintiff, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301, [email protected]
79,550 .5 2 2- 3
EFTA00779732
AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2)
Civil Action No. 08-80893CIV-MARRAMOHNSO
PROOF OF SERVICE
(This section should not befiled with the court unless required by Fed. R. Civ. P. 45.)
This subpoena for (name of individual and title, if any)
was received by me on (date)
O I personally served the subpoena on the individual at (place)
on (date) ; or
O I left the subpoena at the individual's residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual's last known address; or
O I served the subpoena on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
O I returned the subpoena unexecuted because ; or
O Other (specify):
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
My fees are $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc:
EFTA00779733
DataSet-10
Unknown
2 pages
From:
Sent: Thursday, October 18, 2018 11:11 AM
To:
Subject: Re: I was asked 10 years ago many times to write deposition against me
FYI, she doesn't know that you and I met/ sp=ke recently, she only knows of us being acquainted. A few times she was
se=ding out clueless accusations to everyone she knew about them spying on he=, spreading rumors, defamation and
other grandiose nonsense. She also said=she was hearing voices so I told her to go to a free clinic where she can =et an
opinion on the possibility of schizophrenia. She ended up being hosp=talized for 5 days.
I'm un=ertain what diagnosis/treatment she got.
=div dir="auto">Yay thank you so much and likewise, I was so happy to see=you!!! I failed my impromptu yoga
assignment— you should see morek!
wr, 18 =D0'$icr. 2018 r. s 6:58, J depoisition / no idea. -- btw , you=looked well. ,
made me happy to see.
On Thu, Oct 18, 2018 at 6:55 AM rote:
showed me this last night but I wasn't sure why she =anted for me to see it because I've never
asked her about any of h=r medication use etc.
She said the othe= night she wasn't feeling well and was seeking help from me and I =old her to go to
Bellevue, why is she showing this to us?
4T, 18 os4>=82. 2018 r. s 6:29,1 deposition against me
To: jeffr=y E. please note
EFTA_R1_01824612
EFTA02619628
The information contained in this communic=tion is
confidential, may be attorney-client privileged, may
constit=te inside information, and is intended only for
the use of the addresse=. It is the property of
JEE
Unauthorized use, disclosure or copying =f this
communication or any part thereof is strictly prohibited
and =ay be unlawful. If you have received this
communication in error, pleas= notify us immediately by
return e-mail or by e-mail to [email protected], and<=r>destroy this communication and
all copies thereof,
including all atta=hments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may =e attorney-client privileged, may
constitute inside information, and is=intended only for
the use of the addressee. It is the property of
JE=
Unauthorized use, disclosure or copying of this
communication or an= part thereof is strictly prohibited
and may be unlawful. If you have r=ceived this
communication in error, please notify us immediately by
=eturn e-mail or by e-mail to [email protected] , and
destroy this communication =nd all copies thereof,
including all attachments. copyright -all rights=reserved
2
EFTA_R1_01824613
EFTA02619629
DataSet-10
Unknown
1 pages
From: "Tonja Haddad Coleman"
To: "'Dee Soli"' , , >,
Subject: RE: Epstein
Date: Mon, 04 Jun 2012 14:17:21 +0000
Thank you- confirming our 1PM appointment to go over Rothstein deposition.
Tonja Haddad Coleman, Esq.
TONJA HADDAD, P.A.
Justice Building
524 South Andrews Avenue
Suite 200 North
Fort Lauderdale, Florida 33301
(954) 337-3716 facsimile
wwwtonjahaddadpa.com
The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If
you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If
you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message.
From: Dee Soli [mailto:
Sent: Monday, June 04, 2012 10:13 AM
To: [email protected];
Subject: Epstein
Attached please find documents received from Roadruck Investigations in regards to for your review.
Dee Soli, Florida Registered Paralegal
FRED HADDAD, P.A.
One Financial Plaza, Suite 2612
Fort Lauderdale Florida 33394
Tel:
Fax: 954-467-3599
Email: or
CONFIDENTIALITY NOTICE: This transmission and any accompanying documents are solely for the use of the intended recipient
and may contain information that is privileged, confidential or otherwise exempt from disclosure under applicable law. If you are not
the intended recipient, you are hereby notified that any disclosures, copying, distribution, or action taken or omitted in reliance on it
is strictly prohibited. If you received this information in error, please notify the sender immediately and delete the original
transmission. The sender does not assume any responsibility for changes made to this message and any attachments after
transmission.
EFTA00936705
DataSet-10
Unknown
1 pages
From:
To: jeevacation
Subject:
Date: Fri, 18 Sep 2009 14:55:40 +0000
John
Is it legal to broadcast a videotaped deposition all over the internet???
The Palm Beach Post is responsible for this leaking to Gawker.com as well as the Buffington
Post.
I found this:
The deposition first has to be transcribed by the sitting court reporter. Generally either of
the attending attorneys can order the deposition transcribed. The transcription is then held
by that attorney to be referred to in the courtroom at trial if needed. The attorney can pick
and choose from the witnesses' statements and refute what that person said in their
deposition in the courtroom. It is not considered ethical for the contents of a deposition to
be used in any other manner other than to refute a witness' statements in a courtroom. The
deposition is generally not filed with the court. And no, it is not public information if it
is not filed with the court. A court reporter may not divulge it's contents either. She is a
notary public and swears in the witnesses and takes down the proceedings in a deposition. If
the deposition IS filed with the clerk's office, then yes, the deposition may be read by
anyone who looks at the court file.
By the way, you look good.
Off to Zorro on Wed. (drag will be gone)
EFTA00770293
DataSet-10
Unknown
3 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
v. No. 17 Civ. 00616 (JGK)
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
LESLEY GROFF and
Defendants.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
OF LESLEY GROFF
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: Lesley Groff
DATE AND TIME: August 24, 2018 at 10:00 a.m.
LOCATION: Boies Schiller & Flexner, LLP
575 Lexington Avenue, 7111 Floor
New York, NY 10022
The videotaped deposition will be taken upon oral examination before Magna Legal
Services, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
' Plaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding
under her real name.
I
EFTA00793314
The video operator shall be provided by Magna Legal Services. This deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the rules of this Court.
Dated: August 10, 2018.
BOLES SCHILLER FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale FL 33301
Bradley J. Edwards, Esq. (Pro Hac Vice)
Stanley Pottinger, Esq.
EDWARDS POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake Cit , UT 84112
2 This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2
EFTA00793315
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of August, 2018, I served the attached
PLAINTIFFS NOTICE OF TAKING VIDEOTAPED DEPOSITON OF WITNESS LESLEY
GROFF via Email to the following counsel of record.
Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
1114 Avenue of the Americas
New York. NY 10036
Counselfor Jeffrey Epstein, and Lesley Groff
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Counselfor Ghislaine Maxwell
By: /s/ Sigrid McCawley
Sigrid McCawley
3
EFTA00793316
DataSet-10
Unknown
5 pages
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
B.B.,
CASE NO. 502008CA0373193OOOCMB AB
Plaintiff,
v.
and
Defendants
NOTICE OF TAKING DEPOSITION
DUCES TECUM
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces
tecum (See attached Exhibit "A") of:
DEPONENT DATE & TIME LOCATION OF DEPOSITION
Det. Joseph Recarey February 25, 2010 Prose Court Reporting
do Joanne M. O'Conner, Esq. at 9:30 AM One Clearlake Centre
Jones, Foster, Johnson 250 Australian Avenue South
& Stubbs, P.A. West Palm Beach, FL 33401
505 S. Flagler Drive, #1100
West Palm Beach, FL 33401
upon oral examination, before Prose Court Reporting, a Notary Public, or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken for
the purpose of discovery, for use at trial, or for such other purposes as are permitted under the
applicable Statutes of Rules of Court.
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S Mail to the
following addressees on this 3rd day of February, 2010:
Theodore J Leopold, Esq. Jack Alan Goldberger, Esq.
Spencer T. Kuvin, Esq. Atterbury Goldberger & Weiss, P.A.
Leopold-Kuvin, P.A. 250 Australian Avenue South
2925 PGA Blvd., Suite 200 Suite 1400
EFTA00598945
B.B v. Epstein, et al
Page 2
Palm Beach Gardens, FL 33410 West Palm Beach, FL 33401-5012
Fax: 561 697 2383 Fax: 561-835-8691
Counsel for Plaintiff Co-Counsel for Defendant Jeffrey Epstein
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
515 N. Flagler Drive, Suite 400
Wet a ch, FL 33401
(561)515-3148 Fax
Robe . Critton, Jr.
Florida Bar #224162
Mi mel I Pike
Florida Bar #617296
(Colonel for Defendant Jeffrey Epstein)
EFTA00598946
EXHIBIT "A"
red by you or any
1 Any and all written reports, notes, memoranda or other papers autho
in hard-copy or electronic form,
other member of the Palm Beach Police Department, whether
in including but not limited to
that relate to any law enforcement investigation of Jeffrey Epste
es against Mr. Epstein This
the investigation that resulted in the filing of State criminal charg
members of the Palm Beach
request includes any written communications between you and any
t Agency, any member of the
Police Department, any member of any Federal Law Enforcemen
the State Attorney, any
Unites States Attorney's Office, any member of the Office of
sses and/or any lawyers or
representatives of the media, any civil parties, any civilian witne
representatives of any parents of any civilian witnesses.
of the following
2. Any and all electronic communications (EMAIL) between yo any
in including but not limited to the
relating to any law enforcement investigation of Jeffrey Epste
s against him: (A) any member of
investigation that resulted in the filing of State criminal charge
Federal Law Enforcement Agency,
the Palm Beach Police Department, (13) any member of any
member of the Office of the
(C) any member of the Untied States Attorney's Office, (D) any
radio media outlet, (F) any attorney
State Attorney (E) any member of any print, television, or
or may potentially file a civil
representing any civilian witness or civil party who has filed
complaint against Mr Epstein.
any communications between you
3 Any and all notes, memoranda or reports reflecting
d to any request for exculpatory
and counsel on behalf of Mr. Epstein, including but not limite
evidence.
attempts by you to initiate or
4. Any and all notes, memoranda or reports reflecting any
igation or State prosecution
encourage a federal review of any facet/aspect of the Epstein invest
of Epstein
laints made to the Palm
5 Any and all notes, memoranda or reports reflecting any comp
for any person or parent claiming to
Beach Police Department from any person, parent, or lawyer
other private citizen of Palm
have been a victim of any conduct of Mr Epstein or from any
y 1, 2000 — October 22, 2009.
Beach County relating to any conduct of Epstein from Januar
ion between you or
6. Any and all notes, memoranda, or reports reflecting any communicat
with "A H." in relation to her
and any other member of the Palm Beach Police Department Grand Jury,
before a State
being subpoenaed to testify before or her requested attendance
would testify to and/or any
including but not limited to any discussions regarding what she
with prior to any testimony.
preparation that any law enforcement officer provided her
communication between you or
7. Any and all notes, memoranda, or reports reflecting any
"A H."* or referencing "A.H "* in
any other member of the Palm Beach Police Department with
requested attendance before a State
relation to her being subpoenaed to testify before or her
l sought to discourage her or
Grand Jury where you or any Palm Beach police officer or officia
any Grand Jury proceeding
influence her not to testify or to testify in a certain manner at
involving Mr. Epstein.
EFTA00598947
electronic or otherwise,
8. Any and all agreements, memoranda, and/or notes of any kind,
Department, any member of the Office
between you and any member of the Palm Beach Police
Attorney's Office relating to any
of the State Attorney, and/or any member of the United States
any time.
criminal charges, formal or otherwise, regarding "A II " at
communications between you
9. Any and all notes, memoranda, or reports of meetings or
"•
and "S.G "*, her parents, or any lawyers who represent "S.G_
you, and all requests for
10. Any and all records of expenditures made or incurred by
Epstein.
expenditures relating to the criminal investigation of Mr.
s, memoranda or notes, and
11. Any and all logs, pictures, videos, digital information, report
of and/or maintenance of any video
any record of expenditure, which relate to the institution
during the following time periods:
surveillance of Mr. Epstein, his residence, or his visitors
a January 1, 2004-December 31, 2004
b. January 1, 2005-December 31, 2005
c January 1, 2006-December 31, 2006
d. January 1, 2007-December 31, 2007
e. January 1, 2008-December 31, 2008
f. January 1, 2009-today's date.
expenditures or any other
12. Any and all reports, logs, pictures, videos, notes, records of
in, his residence, his visitors, or
memoranda relating to any physical surveillance of Mr. Epste
or co-conspirator other than the
any individual who was believed to be a potential witnesses
request number 11
information relating to video surveillance that is requested in
notes, and reports of any
13. Any and all reports (including forensic reports), memoranda,
nce in October 2005 or on any
examination of any computer seized fiom Mr. Epstein's reside
other occasion.
or burglary
14. Any and all reports, memoranda, or notes reflecting a criminal theft
prior to October 2005.
investigation of Mr. Epstein or his residence on any occasion
cell phone, used by you
15. All cell phone records, both official cell phone and personal
between during the following time periods:
a. January 1, 2004-December 31, 2004
b. January 1, 2005-December 31, 2005
c. January 1, 2006-December 31, 2006
d. January I, 2007-December 31, 2007
e January 1, 2008-December 31, 2008
f. January 1, 2009-today's date.
periods between October 1,
16.. All calendars or diaries, electronic or hard-copy, kept for the
activities, meeting, etc.
2004 up through and including today, reflecting your schedules,
EFTA00598948
17. Any and all reports, memoranda, and notes of any communication between Los and any
member of the Office of the State Attorney relating to the criminal investigation and subsequent
prosecution of Mr. Epstein from October 1, 2004 up through and including today.
18. All policies and procedures of the Palm Beach Police Department setting forth the
procedures for police officers, including the Chief, any detective and officers when commenting
to any media outlets, including but not liming to the local news, the national media, print outlets,
and any web-based media format.
19. All personal notes contained either on your personal computer, work computer, and those
that are handwritten containing any witnesses that you, or any other member of the Palm Beach
Police Department interviewed or attempted to interview with regard to the Epstein investigation
from January 1, 2004, up thorough and including today.
20. Any and all audio tapes of any witnesses that You or any member of the Palm Beach
Police Department obtained statements or interviews from, either sworn or informal, with regard
to the Epstein investigation
21. Any and all audio tapes, notes (hand-written or typed), memoranda, reports, messages,
and/or any communications obtained or generated by you or any member of the Palm Beach
Police Department, either sworn or informal, that relate to Jane Doe #4**, who is the Plaintiff in
a Federal Civil Case No. 08-80380 filed against Jeffrey Epstein.
* The initials Ail. and S.R. refer to the individuals identified in the Palm Beach County
Probable Cause Affidavit ns it relates to the Jeffrey Epstein investigation. Should ou
re uire the complete name of the individuals, please contact Jessica Cadwell at
** Should you need the full identity of Jane Doe #4, please contact Jessica Cadwell at ■
EFTA00598949
DataSet-10
Unknown
2 pages
From: "Harry Susman"
To: "Darren Ind ke" "Stephen D. Susman"
"Jeffrey Epstien" [email protected]>, "Seth
ill M. Dunseth" <
Subject: Fwd: Lee deposition
Date: Thu, 02 Jun 2011 15:03:00 +0000
Attachments: 53111_Lee.txt
Harry Susman
work)
en rd:rn my I Phone
Begin forwarded message:
From: "Laurie Collins"
To
Subject: Re: Lee deposition
Counsel:
Attached is a rough ASCII version of yesterday's deposition of David Lee
taken in the Fortress matter. It is designated as confidential. Final
transcripts will be delivered Monday.
Laurie Collins, Court Reporter
Veritext Court Reporting
On Wed, Jun 1, 2011 at 4:54 PM, Laurie Collins <
wrote:
Counsel:
I understood from Mr. Susman that regular delivery (8-10 business days) is
all that was needed for today's deposition of David Lee. If anyone needs
faster delivery and/or a rough transcript, please let me know.
EFTA01165405
Laurie A. Collins, Court Reporter
Veritext Court Reporting
Laurie A. Collins, Court Reporter
porting
EFTA01165406
DataSet-10
Unknown
120 pages
- rl g 3
Original Transcript
• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
MARK EPSTEIN
September 21, 2009
• 11:30 a.m.
One Penn Plaza,
New York, New York
Jacklyn Lisi
•
Toll Free
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0 Suite 1300
515 East Las Olas Boulevard
ESQUIRE Fort Lauderdale, FL 33301
www.esquiresolutIons.com
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1
• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION of MARK EPSTEIN, taken by
• Defendants, at the offices of Esquire Deposition Solutions,
One Penn Plaza, New York, New York 10119, on Monday,
September 21, 2009, commencing at 11:30 a.m., before Jacklyn
Lisi, a Shorthand Reporter and notary public, within and for
the State of New York.
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Mark Epstein September 21, 2009
2
1
2
APPEARANCES :
ROTHSTEIN ROSENFELDT ADLER, ESQS.
•
Attorneys for Plaintiffs, EW, LM and Jane Doe
3 Las Olas City Centre, Suite 1650
401 East Las Olas Boulevard
4 Fort Lauderdale, Florida 33301
5 BY: BRAD J. EDWARDS, ESQ.
6
7 LEOPOLD KUVIN, ET AL
Attorneys for Plaintiff, BB
8 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
9
BY: ADAM LANGINO, ESQ.
10 (via telephone)
11
COHEN & GRESSER, LLP
12 Attorneys for the Witness, Mark Epstein
100 Park Avenue
13 New York, New York 10017
14
15
BY: MARK S. COHEN, ESQ.
ALEXIS G. STONE, ESQ. •
16
PODHURST ORSECK, et al
17 Attorneys for Plaintiffs, Jane Does 101 and 102
25 West Flagler Street, Suite 800
18 Miami, Florida 33130
19 BY: KATHERINE EZELL, ESQ.
(via telephone)
20
21
MERMELSTEIN & HOROWITZ, ESQS.
22 Attorneys for Plaintiffs, Jane Does 2 through 8
18205 Biscayne Boulevard, Suite 2218
23 Miami, Florida 33160
24 BY: ADAM H. HOROWITZ, ESQ.
(via telephone)
25
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Mark Epstein September 21, 2009
3
• 1
2
APPEARANCES (continued)
RICHARD H. WILLITS, ESQ.
3 Attorney for Plaintiff, ■
2290 10th Avenue North, Suite 404
4 Lake Worth, Florida 33461
(via telephone)
5
6 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
Attorneys for the Defendant, Jeffrey Epstein
515 North Flagler Drive, Suite 400
West Palm Beach, Florida 33401
BY: ROBERT CRITTON, ESQ.
(via telephone)
*
• 11
12
13
14
15
16
17
18
19
20
21
22
23
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Mark Epstein September 21, 2009
•
4
1 STIPULATIONS
2
3 IT IS HEREBY STIPULATED, by and between the attorneys
4 for the respective parties hereto, that all rights provided
5 by the C.P.L.R., and Part 221 of the Uniform Rules for the
6 Conduct of Depositions, including the right to object to any
7 question, except as to form, or to move to strike any
8 testimony at this examination is reserved; and in addition,
9 the failure to object to any question or to move to strike
10 any testimony at this examination shall not be a bar or
11 waiver to make such motion at, and is reserved to, the trial
12 of this action.
13 This deposition may be sworn to by the witness being
14
15
examined before a Notary Public other than the Notary Public
before whom this examination was begun, but the failure to
•
16 do so or to return the original of this deposition to
17 counsel, shall not be deemed a waiver of the rights provided
18 by Rule 3116 of the C.P.L.R. and shall be controlled
19 thereby.
20 The filing of the original of this deposition is
21 waived.
22
23
24
25
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Mark Epstein September 21, 2009
5
• 2
M. Epstein
THE REPORTER: Please state your name
3 and address for the record?
4 THE WITNESS: (Witness refused to give
5 his address to the court reporter.)
6 MR. COHEN: On the record.
7 For the witness, Mark Epstein, Mark
8 Cohen and Alexis Stone of Cohen & Gresser, 100
9 Park Avenue, New York, New York.
10 MR. EDWARDS: Brad Edwards on behalf
11 of EW, LM and Jane Doe.
12 MR. CRITTON: Robert Critton on
13 behalf of Jeffrey Epstein.
• 14
15
MS. EZELL:
Jane Does 101 and 102.
Kathy Ezell on behalf of
16 MR. HOROWITZ: Adam Horowitz on
17 behalf of Plaintiffs, Jane Does 2 through 8.
18 MR. WILLITS: Richard Willits on
19 behalf of
20 MR. LANGINO: Adam Langino on behalf
21 of Plaintiff, BB.
22 MR. EDWARDS Okay. That's everybody.
23 MR. COHEN: Okay. Before I start,
24 this is Mark Cohen on behalf of Mark Epstein,
25 I just want to put on the record the details
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Mark Epstein September 21, 2009
•
6
1 M. Epstein
2 of a conversation I've had with Mr. Edwards
3 and make sure that all counsel is agreeable to
4 this.
5 My client, Mark Epstein, is very
6 concerned about being videotaped and having
7 his image recorded.
8 He is concerned about possible future
9 uses of his image. And so Mr. Edwards and I
10 have agreed that this recording, the videotape
11 of my client, will be confidential and will
12 not be revealed in public unless and until
13 there is an order by a court in one of the
14
15
cases that are involved in these depositions
that orders that the video be made public.
•
16 We are prepared to proceed on that
17 basis.
18 As I understand, Mr. Edwards is
19 prepared to proceed, but obviously we need the
20 agreement of all counsel.
21 MR. WILLITS: Richard Willits agrees.
22 MR. CRITTON: Robert Critton agrees.
23 MS. EZELL: Kathy Ezell agrees.
24 MR. EDWARDS: Adam?
25 MR. HOROWITZ: Adam Horowitz, that's
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Mark Epstein September 21, 2009
7
• 1
2 fine.
M. Epstein
3 MR. LANGINO: The same with Adam
4 Langino, that's fine.
5 MR. COHEN: All right. Thank you.
6 MR. EDWARDS And Sid Garcia is not in
7 and he is not supposed to be in; right?
8 MR. CRITTON: This is Bob Critton.
9 I assume -- I don't know whether he
10 was going to come or not, but I assume that
11 everyone will also abide and not give Mr.
12 Garcia a copy of the video until he also
13 affirms in writing to Mr. Cohen that he's
• 14
15
agreed to be bound by the same agreement.
MR. EDWARDS: Okay.
16 THE VIDEOGRAPHER: This is tape
17 number one to the videotape deposition of Mark
18 Epstein in the matter of Jane Doe versus
19 Jeffrey Epstein being held before the United
20 States District Court in the Southern District
21 of Florida, case file number 08-80893.
22 This deposition is being held at
23 Esquire Deposition Solutions, One Penn Plaza,
24 New York, New York on September 21, 2009. The
25 time is 11:41 a.m.
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Mark Epstein September 21, 2009
•
8
1 M. Epstein
2 My name is Peter Ledwith. I'm the
3 videographer. The court reporter is Jackie
4 Lisi.
5 Counsel, will you please introduce
6 yourselves and who you represent?
7 MR. EDWARDS: Brad Edwards. I
8 represent EW, LM and Jane Doe.
9 MR. COHEN: Mark Cohen and Ally
10 Stone. I represent the witness, Mark Epstein.
11 MR. CRITTON: Robert Critton on
12 behalf of the defendant, Jeff Epstein.
13 MR. WILLITS: Richard Willits on
14
15
behalf of
MR. LANGINO: Adam Langino on behalf
•
16 of Plaintiff BB.
17 MR. HOROWITZ: Adam Horowitz on
18 behalf of plaintiffs Jane Does numbers 2
19 through 8.
20 THE VIDEOGRAPHER: Will the court
21 reporter please swear in the witness?
22 MARK EPSTEIN,
23 having been first duly affirmed, was examined
24 and testified as follows:
25 THE WITNESS: I am an atheist, but I
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Mark Epstein September 21, 2009
9
• 1
2
M. Epstein
will affirm I'll tell the truth.
3 EXAMINATION BY
4 MR. EDWARDS:
5 Q. Can you tell us your name?
6 A. Mark Epstein.
7 THE VIDEOGRAPHER: Can you put the
8 microphone on your shirt, please?
9 THE WITNESS: Mark Epstein.
10 Q. Okay. And your date of birth,
11 please?
12 A.
13 Q• And what is your relationship with
• 14
15
the defendant in this case, Jeffrey Epstein?
A. He is my brother.
16 Q. Are you currently married?
17 A. No.
18 Q. What is your current address?
19 A. I'm not giving out my address. I'm
20 concerned about my personal safety because of
21 the nature of this case. You can use his
22 address. You can use my attorney's address.
23 Q. Please elaborate on that for me that
24 you are concerned for your safety because of
25 the nature of this case?
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Mark Epstein September 21, 2009
•
10
1 M. Epstein
2 A. Because I've read -- well, I know
3 that Jeffrey hired a detective or someone from
4 the police when he went out on his days out.
5 So obviously there is probably a concern for
6 safety.
7 I don't want anything to do with this
8 case. I have nothing to do with this case. I
9 don't want my identifying information on any
10 kind of public record.
11 MR. COHEN: If it will make it
12 easier, Mr. Edwards, this is Mark Cohen
13 speaking. Mr. Mark Epstein is authorizing my
14
15
firm to accept service if there is a future
subpoena or a need to contact him again.
•
16 THE WITNESS: Before we go on, I want
17 to make a statement.
18 I want to say on the record that
19 initially I was improperly served with a
20 subpoena from Florida, it was supposed to come
21 from New York.
22 It also did not include the required
23 documents giving me my rights and obligations
24 under the Florida laws. So it's a breach of
25 some kind of ethics.
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Mark Epstein September 21, 2009
11
M. Epstein
2 So in my book, you are either
incompetent, devious or have no ethical
compass.
So you are not on my high list.
6 Continue with your questions. I just wanted a
7 record of that.
8 MR. CRITTON: Brad, can you move the
9 phone a little closer to Mr. Epstein? I heard
10 you and I heard Mr. Cohen fine, but I'm having
11 trouble with Mr. Epstein.
12 MR. EDWARDS: All right.
13 MR. CRITTON: Thank you.
• 14
15
MR. EDWARDS: I apologize for your
feelings about the subpoena.
16 THE WITNESS: Not accepted.
17 This is too serious of a matter.
18 BY MR. EDWARDS:
19 Q. You do realize that you are
20 subpoenaed to testify today in cases that
21 involve your brother having sex or engaging in
22 sex acts with minors; correct?
23 MR. CRITTON: Form?
24 MR. COHEN: That's --
25 A. I know there is a case against my
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Mark Epstein September 21, 2009
•
12
1 M. Epstein
2 brother. I know that.
3 Q. And you are aware that there are
4 multiple attorneys on the phone that represent
5 girls who were under-age when Mr. Epstein had
6 sex with them?
7 A. I know there are multiple attorneys
8 on the phone.
9 Q. Okay. Have you read the newspaper
10 articles about your brother that detail your
11 brother having sex with under-age girls?
12 MR. CRITTON: Form.
13 A. I've read some of the papers.
14
15
Q.
wrong?
You agree that sex with minors is •
16 MR. CRITTON: Form.
17 MR. COHEN: Objection.
18 Q. You can answer.
19 A. I have no opinion on that.
20 Q. Okay.
21 A. I'm not here to give opinions. I'm
22 here for facts. So ask me questions about
23 facts and I'll be glad to answer them.
24 Q. Well, do you agree with the laws that
25 protect under-age children from adult sexual
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Mark Epstein September 21, 2009
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• 1
2 predators?
M. Epstein
3 MR. COHEN: Objection.
4 MR. CRITTON: Form.
5 A. My information on the case is my
6 brother I know had to spend sometime in jail
7 for some prostitution charge.
8 So I assume the attorneys are
representing the prostitutes he was involved
10 with, so I don't know what the ages of them
11 are or were.
12 I'm not involved with the case. I
13 don't watch all the details about it. That's
• 14
15
all.
Q. Would it surprise you to learn that
16 there were more than 30 girls between the ages
17 of 12 and 15 that your brother engaged in sex
18 acts with?
19 MR. CRITTON: Form.
20 A. I don't get surprised by very many
21 things in this world.
22 Q. But you and your brother are a year
23 apart; right?
24 A. 18 months.
25 O. And you grew up together?
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Mark Epstein September 21, 2009
14
1 M. Epstein •
2 A. Sure.
3 Q• You still talk to him?
4 A. Occasionally, rarely.
5 Q. So when I ask you, does it surprise
6 you, you are saying that it doesn't surprise
7 you that your older brother engaged in sex
8 with more than 30 girls between 12 and
9 15 years old?
10 MR. COHEN: Objection.
11 MR. CRITTON: Form.
12 A. I don't know how to answer that
13 question. I don't know if it's true, and I
14
15
don't know what the story is.
It's not -- ask me a question about
•
16 facts I'm not going to give you opinions
17 here, that's not what I'm here for.
18
19
20
21
22
23
24
25
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Mark Epstein September 21, 2009
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M. Epstein
3
4
6
7 MR. EDWARDS: Counsel?
8 MR. COHEN: I would suggest you move
9 to an area that's likely to lead to you
10 gathering relevant evidence.
11 We can come back to this burning
12 question maybe later.
13 MR. CRITTON: Let me also add that I
• 14
15
can only object to form, but I also want to
put on the record, other than his name and he
16 is related to Mr. Epstein, there is not one
17 piece of evidence or --
18 THE COURT REPORTER: I can't hear
19 you.
20 MR. CRITTON: I'm sorry. I just want
21 to note for the record that other than his
22 name and his relationship to Mr. Epstein, to
23 Jeffrey Epstein, there has been nothing of
24 relevance or materiality that would lead to
25 admissible evidence at the time of trial.
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Mark Epstein September 21, 2009
•
16
1 M. Epstein
2 This is being done to harass or
3 humiliate Mr. Mark Epstein and/or my client.
4 It certainly borders on that, but he is not an
5 expert, his opinions are irrelevant in this
6 case, and as is his own family situation
7 but --
8 MR. EDWARDS: Mr. Critton, as you
9 stated first, I think that your objection is
10 limited to the form. Thanks.
11 Can I mark this as an exhibit?
12 (Plaintiff's Exhibit 1 was so marked
13 for identification.)
14
15
MR. COHEN: I will say that I join in
Mr. Critton's objection for the record.
•
16 BY MR. EDWARDS:
17 Q. How frequently do you talk with your
18 brother now?
19 A. Maybe once every couple of weeks or
20 so, but "now° being just the last month or
21 two.
22 Q. Okay. When you first learned of a
23 criminal investigation into your brother, did
24 you talk to him about the substance of those
25 allegations?
0
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Mark Epstein September 21, 2009
17
M. Epstein
2 A. No.
3 Q. Have you ever asked him or had a
4 conversation with him about the allegations
5 that he's had sex with numerous under-age
6 kids?
7 A. No.
8 Q. Is there a reason why you wouldn't
9 ask him questions about him engaging in sex
10 with 13, 14-year old kids?
11 A. We are not very close. We don't talk
12 very often.
13 MR. CRITTON: Form.
• 14 Q. But when you do talk to him, that
15 conversation doesn't come up?
16 A. No.
17 Q. He went to jail. Did he ever tell
18 you why he went to jail?
19 A. No.
20 Q. Are you familiar with the property at
21
22 A. Yes, I am.
23 Q. Who owns that property?
24 A. Dara Partners.
25 Q. And what is Jeffrey Epstein's
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Mark Epstein September 21, 2009
18
1
2
M. Epstein
affiliation with that property?
•
3 A. He rents some apartments in there.
4 Q. How many apartments does Jeffrey
5 Epstein rent at
6 A. It's either 8 or 10, I am not sure.
7 Q. Who are the residents of the
8 apartments that Jeffrey Epstein rents at that
9 location?
10 A. I have no idea.
11 MR. CRITTON: Brad, what was the
12 answer to the last one?
13 MR. COHEN: He has no idea.
14
15
A. I know his pilots used to stay there,
but I don't think he is using pilots any more.
•
16 Q. Why does he rent so many places at
17 the same location?
18 A. I have no idea.
19 Q. Have you ever had any affiliation
20 with that location?
21 A. Sure.
22 Q. In what way?
23 A. I'm one of the partners of Dara
24 Partners.
25 Q. So does your brother rent from you?
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EFIA_00108568
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Mark Epstein September 21, 2009
19
• 1
2 A.
M. Epstein
No, he rents from Dara Partners. My
3 partner handles that property, I don't know
4 any of the tenants in that building other than
5 one or two.
6 Q. What are the names of the one or two
7 that you do know?
8 A. It is my ex, so I'm not going to give
9 you her name.
10 Q. Is that somebody who lives in one of
11 the places rented by your brother Jeffrey
12 Epstein?
13 A. No.
• 14
15
Q. Do you know any of the tenants that
live in the places rented by your brother,
16 Jeffrey Epstein?
17 A. No.
18 Q. Do you know
19 A. I know the name. I don't know her.
20 Q. Do you know what her relationship is
21 to your brother?
22 A. I think she worked for him.
23 Q. In what capacity?
24 A. I have no idea.
25 Q. Do you know if she lives in
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Mark Epstein September 21, 2009
•
20
1 M. Epstein
2
3 A. I don't know where she lives.
4 Q. Would you know her if you saw her?
5 A. No.
6 Q. You've never seen her before?
7 A. I might have seen her somewhere, I
8 don't know.
9 Q. Have you ever talked to her?
10 A. I don't recall talking to her.
11 Q. Do you know
12 A. I know of her.
13 Q. How do you know of her?
14
15
A.
Q.
In the papers.
What papers?
•
16 A. Newspapers. I read some articles.
17 Q. Newspapers about your brother?
18 A. Relating to his case, yes.
19 Q. Okay. And what is your understanding
20 of her relationship with your brother?
21 A. I don't have an understanding about
22 it.
23 MR. CRITTON: Form.
24 A. My brother and I do not have a close
25 relationship, so what he does is his business
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DataSet-10
Unknown
220 pages
Page I
1 UNITED STATES BANKRUPTCY COURT
SOUTHER DISTRICT OF FLORIDA
2 FORT LAUDERDALE DIVISION
3
4 IN RE: NO.: 09-34791-RBR
5 ROTHSTEIN ROSENFELDT ADLER, P.A.
6
7
8 VIDEOTAPED
9 DEPOSITION
10 OF
11 JOHN JACK SCAROLA
12
13
14
15 350 East Las Olas Boulevard
Fort Lauderdale, Florida
16 July 2, 2013
Scheduled for 10:00 a.m.
17 Commencing at 10:07 a.m. to 5:23 p.m.
18
19
20
21
22
23
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130416
Page 2
1 UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
2 FORT LAUDERDALE DIVISION
3
4 IN RE: CHAPTER 7
5
BANYON 1030-32, LLC CASE NOS: 10-36691-RBR
6 BANYON INCOME FUND, L.P. 11-40929-RBR
7 Debtors. Jointly Administered Under
Case No. 10-33691-RBR
8
/
9
10
11
12 VIDEOTAPED
13 DEPOSITION
14 OF
15 JOHN JACK SCAROLA
16
17
18
19 350 East Las Olas Boulevard
Fort Lauderdale, Florida
20 July 2, 2013
Scheduled for 10:00 a m.
21 Commencing at 10:07 a.m. to 5:23 p.m.
22
23
24
25
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
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Page 3
1 APPEARANCES:
2 On behalf of TD Bank, N.A.:
WILLIAM O.L. "WEN" HUTCHINSON, Esquire
3 JOSEPH SHEERIN, Esquire
MCGUIREWOODS
4 201 North Tyron Street
Suite 3000
5 Charlotte, North Carolina 28202
6 On behalf Herbert Stettin, Trustee:
JOHN H. GENOVESE, Esquire
7 MICHAEL A. FRIEDMAN, Esquire
GENOVESE JOBLOVE & BATTISTA, P.A.
8 100 Southeast Second Street
44th Floor
9 Miami, Florida 33131
-and-
10 DAVID GAY, Esquire
BERGER SINGERMAN
11 350 East Las Olas Boulevard
Suite 1000
12 Fort Lauderdale, Florida 33301
13 On behalf of Robert Furr, Trustee:
JASON S. RIGOLI, Esquire
14 FURR & COHEN, P.A.
One Boca Place, Suite 337W
15 2255 Glades Road
Boca Raton, Florida 33431
16
On behalf of the Plaintiffs:
17 ADAM MOSKOWITZ, Esquire
KOZYAK TROPIN & THROCKMORTON, P.A.
18 2525 Ponce de Leon Boulevard
Ninth Floor
19 Miami, Florida 33131-2335
20 On behalf of the Plaintiffs:
William Scherer, Esquire
21 CONRAD & SCHERER, LLP
633 South Federal Highway
22 Eighth Floor
Fort Lauderdale, Florida 33301
23
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130418
Page 4
1 CONT. APPEARANCES:
2 On behalf of Unsecured Creditors Committee:
MICHAEL J. GOLDBERG, Esquire
3 350 East Las Olas Boulevard
Suite 1600
4 Fort Lauderdale, Florida 33301-2229
5 On behalf of Morse Operations and
The Estate of Ed Morse:
6 JOHN M. MULLIN, Esquire
TRIPP SCOTT
7 110 Southeast Sixth Street
Fifteenth Floor
8 Fort Lauderdale, Florida 33301
9
10 ALSO PRESENT:
11 Patricia Diaz, FPR, RPR
12 Dean J. Chimerakis, Videographer
Custom Video Services, Inc.
13
14
15
16
17
18
19
20
21
22
23
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130419
Page 5
1 INDEX
2 WITNESS: PAGE
3 JOHN JACK SCAROLA
4 DIRECT EXAMINATION BY MR. HUTCHINSON 7
CROSS-EXAMINATION BY MR. GENOVESE 173
5 CROSS-EXAMINATION BY MR. MOSKOWITZ 216
6
7
8 EXHIBITS
9 -
10 NO. DESCRIPTION PAGE
11 Exhibit No. 1 Subpoena 7
12 Exhibit No. 2 Subpoena for Christian 9
Searcy
13
Exhibit No. 3 Transcript of May 17, 2013 48
14 Hearing
15 Exhibit No. 4 Plaintiff's First Request 68
for Production of Documents
16 to TD Bank
17 Exhibit No. 5 TD Bank Victims Notice of 79
Filing Expert Disclosures
18
Exhibit No. 6 Time Summary 81
19
Exhibit No. 7 Conspiracy Chart 111
20
Exhibit No. 8 Statute 768.72 124
21
Exhibit No. 9 Statute 768.73 148
22
Exhibit No. 10 Handwritten Notes 163
23
Exhibit No. 11 Handwritten Notes 168
24
25
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130420
Page 6
1 THE VIDEOGRAPHER: Today's date is July 2nd,
2 2013. The time is approximately 10:10 a.m. Eastern
3 Standard Time. We are here to videotape the
4 deposition of John Jack Scarola in regard to
5 Rothstein, Rosenfeldt, Adler, PA, Case 09-34791
6 BKCRVR.
7 The court reporter is Patty Diaz with
8 Ouellette and Mauldin Court Reporting. My name is
9 Dean Chimerakis, videographer, with Custom Video
10 Services of Miami.
11 Will counsel please state your appearance for
12 the record?
13 MR. HUTCHINSON: Wayne Hutchinson with
14 McGuireWoods on behalf of TD Bank, N.A., and with
15 me is Joe Sheerin.
16 MR. GENOVESE: John Genovese, Genovese,
17 Joblove and Battista on behalf of Herb Stettin.
18 Along with me is my colleague, Michael Friedman.
19 MR. RIGOLI: Jason Rigoli, Furr & Cohen on
20 behalf of Robert Furr, Chapter 7 Trustee for Banyon
21 1030-32 and Banyon Income Fund.
22 MR. MOSKOWITZ: Adam Moskowitz, Bill Scherer
23 and Javi Lopez on behalf of the plaintiffs in the
24 case.
25 MR. MULLIN: John Mullin from Tripp, Scott on
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130421
Page 7
1 behalf of the Estate of Ed Morse and Morse
2 Operations, Inc.
3 MR. GOLDBERG: Mike Goldberg on behalf of the
4 Creditors Committee.
5 MR. GAY: David Gay with Berger Singerman
6 counsel on behalf of Herbert Stettin.
7 Thereupon,
8 JOHN SCAROLA
9 was called as a witness and, having been duly sworn, was
10 examined and testified as follows:
11 THE WITNESS: I do.
12 DIRECT EXAMINATION
13 BY MR. HUTCHINSON:
14 Q. Good morning, Mr. Scarola. We met before the
15 deposition. Would you please state your name for the
16 record?
17 A. Good morning. My name is John Scarola. I am
18 also most commonly known as Jack.
19 Q. Mr. Scarola, I will show you what I marked as
20 Exhibit 1. Do you recognize Exhibit 1?
21 (Exhibit No. 1, Subpoena, was marked for
22 identification.)
23 A. It appears to be a copy of the subpoena for
24 this deposition that was served upon my office and
25 accepted at my direction.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130422
Page 8
1 BY MR. HUTCHINSON:
2 Q. And are you appearing here today pursuant to
3 this subpoena?
4 A. I am.
5 Q. And this subpoena includes a document request,
6 does it not?
7 A. It does.
8 Q. And have you produced all documents that are
9 responsive to the request included therein?
10 A. I believe I have.
11 Q. Does that include some documents that you have
12 brought with you here today?
13 A. That is correct.
14 Q. Based on what was previously produced and what
15 you brought here today, you believe that all documents
16 responsive to these requests have now been provided.
17 Correct?
18 A. I don't have personal knowledge of the
19 production that was not made by me. I am told that you
20 have already received duplicate copies of most of the
21 materials that I brought today, but I have brought with
22 me all of those materials in my possession that are
23 responsive to the subpoena.
24 Q. And you are fine with us looking through those
25 materials to confirm that we have them and if not,
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130423
Page 9
1 making any copies that we need to make so that we have
2 them for our records?
3 A. Yes. I know that there are documents that are
4 included in the group of documents that I brought this
5 morning that were not produced to you because they are
6 my personal notes with regard to my review of the other
7 materials.
8 Q. But you are not aware of any additional
9 materials that either have not been provided or are not
10 with you here today?
11 A. I am not.
12 Q. Let me show you what I marked -- is marked as
13 Exhibit 2.
14 (Exhibit No. 2, Subpoena for Christian Searcy,
15 was marked for identification.)
16 A. Yes, sir.
17 BY MR. HUTCHINSON:
18 Q. Do you recognize Exhibit 2, sir?
19 A. I do.
20 Q. What is Exhibit 2?
21 A. Exhibit 2 is a copy of a subpoena that was
22 accepted by my office on behalf of Christian Searcy and
23 I have seen a copy of this subpoena as well.
24 Q. And am I correct that this subpoena also
25 includes certain document requests?
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130424
Pagc 10
1 A. It does.
2 Q. And we have not received a separate response
3 to this subpoena from your law firm. Is your document
4 production individually supposed to respond to this
5 subpoena as well?
6 A. It is.
7 Q. So as we sit here today, you have no knowledge
8 of additional documents responsive to the request,
9 including Exhibit 2, that are responsive therein that
10 have not either been provided to us previously or are
11 not in the materials that you brought here today?
12 A. That is correct. Certainly, it's possible
13 that I may have overlooked something, but I don't think
14 SO.
15 Q. Mr. Scarola, in what fields are you an expert?
16 A. I am a trial lawyer who has been practicing in
17 the area of litigation since 1972. I am Board-certified
18 in personal injury and in business litigation as well
19 and I believe that both certifications have been in
20 place since they were offered by the Florida Bar.
21 Q. And if you were going to list the fields in
22 which you believe that you are an expert, what fields
23 how would you describe those fields and what would they
24 be?
25 A. Well, for purposes of the deposition today, I
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130425
Pagell
1 have been asked to express opinions with regard to the
2 punitive damage value of claims against TD Bank and I
3 present myself as having sufficient expertise in that
4 area to express those opinions.
5 Q. So it's your understanding that your opinions
6 in this matter are limited to the value of potential
7 punitive damages claims against TD. Is that correct?
8 A. That certainly is the primary focus of what I
9 have been asked to do, and while I may have formed some
10 tangential opinions that relate to that primary area,
11 that is the focus of what I have done.
12 Q. What qualifies you as an expert on punitive
13 damages and the values of punitive damages claims?
14 A. The total of 40 years experience that I have
15 had litigating both criminal and civil cases, including
16 many punitive damages claims.
17 Q. At what point during that 40-year career did
18 you become an expert on valuating punitive damages
19 claims?
20 A. I cannot tell you the point in time at which
21 someone would have independently recognized my
22 expertise. It has been an evolving process, so that's a
23 question that I can't answer for you, except to tell you
24 that it is my personal assessment that I am certainly
25 there now.
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1 Q. Are there any specific factors that you
2 believe makes you qualified to be an expert on the
3 valuation of punitive damages claims other than your
4 general experience?
5 A. Yes. It is an area of the law that I have
6 studied. It is an area of the law that I have focused
7 study upon. That is, I am sure that over the course of
8 particularly the last 35 years I have taken CLE courses
9 that have dealt with the topic of punitive damages as
10 well as having taught multiple courses dealing with the
11 topic of punitive damages.
12 So, it is as a consequence of practical
13 experience, formal education and self-study that I have
14 accumulated the degree of expertise that I have in this
15 area.
16 Q. Let's talk about the CLE courses that you have
17 taught that deal with the valuation of punitive damages
18 claims. Can you please tell me about those courses,
19 their titles and when they were offered?
20 A. I'm sorry, but I cannot give you the course
21 titles nor can I tell you the specific dates on which
22 the courses were offered.
23 What I can tell you is that I have lectured on
24 both the state and local level on the topic of punitive
25 damages and have also been invited to give lectures on
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130427
PagcB
1 punitive damages in front of at least one other state
2 Bar Association.
3 Q. What state Bar Association was that that you
4 are referring to?
5 A. Ohio.
6 Q. Were they the sponsor of the continuing
7 education class?
8 A. They were.
9 Q. And where was that lecture?
10 A. It actually occurred when that Bar Association
11 met in Palm Beach County.
12 Q. And when was that?
13 A. I can't give you the date.
14 Q. Was it in the last five years?
15 A. I'm not sure.
16 Q. What's your best estimate of when that would
17 have been?
18 A. Approximately, five years ago.
19 Q. And did you prepare materials for that CLE
20 presentation?
21 A. I don't know whether I prepared materials
22 specifically for that CLE presentation or whether I
23 relied upon materials previously prepared and having
24 lectured on the topic prior to that lecture.
25 Q. Would you still have the materials that you
OUELLETTE & NIAULDIN COURT REPORTERS, INC.
EFTA01130428
Page 14
1 would have used in these past lectures?
2 A. Probably some of them.
3 Q. Is the information contained in those
4 materials anything that you relied upon in forming the
5 opinions in this case?
6 A. The information contained within those
7 materials include principles that I relied upon in
8 formulating my opinions in this case, I think would be a
9 more accurate way to state the relationship between
10 those materials and my opinion.
11 Q. And to the extent that you can find any of
12 those ---
13 A. You've got them.
14 Q. Okay. Are those materials with you here
15 today?
16 A. They are. If they exist, they are in that
17 box.
18 Q. Thank you very much.
19 A. You are welcome.
20 Q. Other than the lectures at the Ohio State Bar
21 Association, were your other CLE lectures all
22 sponsored -- were the classes all sponsored by the
23 Florida Bar Association?
24 A. No.
25 Q. Who were the other CLE classes sponsored by
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130429
Pagc 15
1 wherein you lectured on punitive damages?
2 A. Palm Beach County Bar Association, Palm Beach
3 County Justice Association, Florida Justice Association.
4 Q. And over how many years did those lectures
5 occur?
6 A. Certainly within the past 20 years, and I
7 don't know that I can accurately narrow it down beyond
8 that. It's a topic that I have been dealing with
9 significantly over at least the last 20 years.
10 Q. Have you lectured on the punitive damages
11 aspect of the Florida Tort Reform Acts that were
12 implemented in the late 1990s?
13 A. I have.
14 Q. What would have been your topics on -- what's
15 been the subject matters of those lectures on those
16 topics?
17 A. The implications from both the legal and
18 practical standpoint of the legislative changes.
19 Q. And what do you recall about those
20 implications?
21 A. I recall that the Florida legislature has,
22 from time to time, been imposing various restrictions on
23 the common law ability to recover punitive damages.
24 Q. In your opinion, does the Florida Legislature
25 have the right to do that?
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1 A. It is my personal opinion that the Florida
2 Legislature has a limited right to deal with imposing
3 restrictions on the ability to recover punitive damages,
4 that there are constitutional limitations on how those
5 restrictions may be imposed.
6 Q. What constitutional limitations are you
7 referring to?
8 A. The due process and equal protection clauses
9 of both the United States Constitution and the Florida
10 Constitution.
11 Q. Are you claiming -- is it your -- are you
12 offering an opinion in this matter that there is a
13 property right with respect to a punitive damages claim?
14 A. No. I am not offering that opinion. I am
15 assuming for purposes of the opinions that I will be
16 expressing today that the current legislative
17 limitations that have been imposed upon the ability to
18 recover punitive damages pass constitutional muster.
19 Q. They do pass constitutional muster?
20 A. I have assumed that for purposes of the
21 opinions that I am expressing today.
22 Q. So, you are not offering an opinion in this
23 matter that the current statutes limiting punitive
24 damage awards are somehow unconstitutional or not
25 applicable to this matter?
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
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Pagc 17
1 A. I am not offering that opinion today.
2 Q. And you are not planning on offering that
3 opinion at the confirmation hearing?
4 A. I don't plan on offering that opinion at the
5 confirmation hearing, no.
6 Q. Let's go back. You talked about that you've
7 lectured on the practical implications of the new -- of
8 the punitive damages tort reform that was implemented in
9 the late 1990s. What is your understanding of the
10 practical implications of those reforms?
11 A. That really is a very broad question and I
12 would prefer that it be more focussed before I attempt
13 to answer it.
14 In what regard?
15 Q. Well, are there limits on the -- the amount of
16 punitive damages? Is it your understanding there are
17 limits on the amount of punitive damages that can be
18 recovered as a result of such reforms?
19 A. Yes, under some circumstances.
20 Q. And what are those circumstances?
21 A. Those that are specifically described in the
22 statute.
23 Q. Do you recall any of those circumstances
24 without referencing the statute?
25 A. I think I can recall some of them without
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130432
Pagc 18
1 referencing the statute. Certainly, if you want the
2 most accurate answer I am able to give you, I've got a
3 copy of the statute in the materials that have been
4 provided, and it would be easier to have it in front of
5 me. But if what you would like to do is test my memory,
6 you know, I will play that game with you.
7 Q. Well, we are not playing games.
8 A. Okay.
9 Q. But what do you recall about the statutory
10 limitations?
11 A. I recall that there are limitations that would
12 impose a three times compensatory damage limit under
13 some circumstances, limitations that impose a four time
14 compensatory damage limitation under some circumstances.
15 There is expressed statutory language that indicates
16 that there is no statutory limitation under other
17 circumstances, and I recall that there is specific
18 language in the statute that indicates that the statute
19 is primarily applicable to products liability claims.
20 Q. Are you offering an opinion in this matter
21 that the statutes are somehow not applicable to the
22 claims at issue?
23 A. It is my opinion that the circumstances of the
24 punitive damage claims against TD Bank take those damage
25 claims outside the statutory limitations.
OUELLETTE & NIAULDIN COURT REPORTERS, INC.
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1 Q. Is that -- is it your opinion that it's
2 outside the statutory limitations because they are not
3 product liability claims?
4 A. It's my opinion that they are outside the
5 statutory limitations for multiple reasons; one, because
6 they are not within those provisions of the statute that
7 impose limitations, but secondly, because the nature of
8 the misconduct is such that I believe that that
9 misconduct takes the claims outside of the statutory
10 limitations.
11 Q. And we will certainly get into that in more
12 detail, but generally, are those the two reasons why you
13 believe that the conduct at issue in the underlying
14 claims in this matter are outside the punitive damages
15 limitations?
16 A. Generally, yes. When we are talking about
17 punitive damages limitations right now, we are simply
18 focusing on statutory limitations.
19 Q. Yes, sir.
20 Did you have any involvement with the punitive
21 damages tort reform that was implemented in the late
22 1990s?
23 A. I am not sure what it is you are asking me.
24 If you are asking whether I had any involvement in
25 formulating the law, the answer to that question is I
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
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Page 20
1 did not.
2 Q. Who did? To your knowledge, who did formulate
3 the law?
4 A. The Florida Legislature.
5 Q. Do you have any idea who wrote the law?
6 A. I don't know the names of any of the
7 draftsmen, and I would be surprised if the end result
8 were not the product of input from multiple sources.
9 Q. Do you have any personal knowledge of that?
10 A. I don't, no, at least none that I recall.
11 There may have been some point in time when I had
12 occasion to attempt to review the legislative history,
13 but I don't remember that.
14 Q. Would the draftsmen of the punitive damages
15 statute be the best resource in terms of trying to
16 determine the intent behind the statutes?
17 A. Not necessarily, no.
18 Q. Who would be?
19 A. The Florida Supreme Court ultimately.
20 Q. And the Supreme Court looks to legislative
21 history at times to determine the intent of the statute;
22 does it not?
23 A. If it is necessary to go beyond the plain
24 meaning of the language of the statute, that is a
25 consideration that the Court might view. I don't -- I
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130435
Pagc 21
1 don't know that that would be necessary under the
2 circumstances of this statute and it certainly does not
3 appear to have been necessary up to this point in time.
4 Q. But you are not going to offer any opinions in
5 this matter on the nature and the intent of the statute
6 beyond the statutory language. Correct?
7 A. That is correct.
8 Q. And you have no personal knowledge of the
9 nature and intent of the enactment of the statute.
10 Correct?
11 A. I do not have any personal knowledge regarding
12 the drafting process nor the deliberative process of the
13 Legislature, nor do I think that either of those matters
14 is relevant.
15 Q. Do you know what groups were involved in the
16 lobbying effort for the tort reform effort?
17 A. I can make reasoned assumptions in that
18 regard, but I don't have any direct knowledge.
19 Q. In addition to the CLE courses you have taken
20 and taught on punitive damages, you also said that you
21 have done a good bit of studies conducted for punitive
22 damage purposes. Is that correct, or you have
23 researched punitive damages?
24 A. I have, yes.
25 Q. Can you please describe those research efforts
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130436
Pagc 22
1 over the years?
2 A. I have read case law. I have read treatises.
3 I have read articles in professional journals. That's
4 what comes to mind immediately.
5 Q. Is there any treatise out there that you have
6 read that you believe to be the most authoritative
7 treatise on the status of damages in the State of
8 Florida?
9 A. There is no treatise that I would accept as
10 generally authoritative on all issues with regard to
11 punitive damages.
12 Q. Is there any treatises that you would accept
13 as authoritative on some of the issues with respect to
14 punitive damages?
15 A. Well, that would depend upon a particular
16 issue and my review of the way in which the treatise
17 treats that issue. So, I can't answer that broadly.
18 Q. Are there any issues in this matter that you
19 intend to opine upon that you believe a certain treatise
20 would be authoritative?
21 A. I have not expressly reviewed any treatise for
22 purposes of formulating my opinions in this matter and
23 ascertaining whether those opinions conform with that
24 treatise so I can't answer that question.
25 What I will tell you is that I have assembled
OUELLETTE & MAULDIN COURT REPORTERS, INC.
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Page 23
1 over the years some fairly extensive research materials
2 with regard to punitive damages. They certainly don't
3 include everything that I have reviewed, but it has been
4 my standard operating procedure as a trial lawyer to
S preserve copies of materials that I think may be of some
6 significance with regard to a matter that I am currently
7 involved in or that I might reasonably anticipate would
8 become relevant to future matters, and I have kept those
9 research files and produced them for you today.
10 I selected from those files the punitive
11 damage files that I thought might be most relevant to
12 the inquiry that is being conducted.
13 Q. Thank you. So you keep a punitive damage --
14 A. I am not sure once you see them you are going
15 to want to say thank you, but I have them here.
16 Q. We appreciate it. How many times ---
17 A. Nor do I think you are going to appreciate it
18 when you get a chance to look at them, but they are
19 here.
20 Q. Thank you.
21 How many times have you testified as an expert
22 on punitive damages?
23 A. I don't have a recollection of ever having
24 served as a punitive damage expert before today.
25 Q. Have you ever been ---
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130438
Pagc 24
1 A. I am a virgin.
2 Q. Have you ever -- I will move on.
3 Have you ever been asked to serve as a
4 punitive damages expert before today?
S A. I have not, no.
6 Q. Have you ever heard of a punitive damages
7 expert before today?
8 A. Certainly not in the context of someone
9 testifying about the value of a punitive damage claim
10 but there are -- there are certainly a lot of folks out
11 there who have training and experience that formulate
12 opinions with regard to the punitive damage value of
13 cases in the ordinary course of their litigation
14 practice.
15 Q. But you have never heard -- how long, sir,
16 have you been litigating cases?
17 A. Since 1972.
18 Q. Since 1972, have you ever heard of another
19 person offering an opinion as to the value of a punitive
20 damages claim?
21 A. Many times, yes.
22 Q. And --
23 A. As a routine matter.
24 Q. Testifying in court?
25 A. No, sir. No. That wasn't the question.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130439
Pagc 25
1 That's not how I understood your question.
2 Q. I'm sorry. Then let me repeat or rephrase my
3 question.
4 Since 1972, have you ever heard or seen
5 someone testify as an expert as to the value of a
6 punitive damages claim?
7 A. You know, as you are asking that question, I
8 am thinking back to one occasion where I believe that,
9 in fact, did occur in a case that I personally
10 litigated.
11 Q. Can you tell me about that case and the
12 circumstances of that testimony?
13 A. Yes. The case was a claim against Bankers
14 Multiple Line Insurance Company. The full style of the
15 case was Farish versus Bankers Multiple Line. It was a
16 tortious interference claim against John D. MacArthur
17 and Bankers Multiple, which was a liability insurer that
18 was owned by MacArthur.
19 Joseph Farish was a trial lawyer who had been
20 hired by the widow of a young man who was walking down
21 the street when a truck came by carrying concrete
22 culverts. The truckload was not properly secured. A
23 culvert fell off the truck and crushed him as he was
24 walking down the street. The truck was owned by a
25 MacArthur Company and insured by Bankers Multiple Line
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130440
Pagc 26
1 Insurance Company.
2 The widow was an employee of John D. MacArthur
3 at a hotel that MacArthur also owned called The
4 Colonnades, and when MacArthur found out about the
5 widow's claim against his company and his insurance
6 company, he befriended the widow and convinced her to
7 terminate the services of MacArthur and to retain the
8 services of a young woman who had virtually no
9 litigation experience whatsoever who proceeded then to
10 settle the widow's claim very cheaply.
11 I represented Mr. Farish in a tortious
12 interference claim, and one of the issues was the value
13 of the underlying case. And there was expert witness
14 testimony that was given in that case about the value of
15 the claim absent the tortious interference.
16 I am blanking on the name of the trial lawyer
17 or trial lawyers who gave that testimony. That was
18 probably 25 years ago.
19 Q. So you did not present such testimony?
20 A. I'm surprised myself by remembering how much I
21 remembered about that.
22 Q. You did not present such testimony?
23 A. I did not present the testimony, no.
24 Q. In all your years of trying cases, have you
25 ever retained an expert to opine on the value of
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130441
Page 27
1 punitive damage claims that you or your client was
2 asserting?
3 A. Only the circumstances that I just described,
4 and -- well, that's the best answer I can give at this
5 time.
6 Q. Other than the research and studies that you
7 have previously described, have you performed any other
8 type of research during your career that supports your
9 purported expertise?
10 A. The process of evaluating punitive damages
11 claims is a process that goes on on a very frequent
12 basis in the course of my practice. So, to that extent,
13 the answer to your question is certainly yes.
14 Q. So you are saying you evaluate the punitive
15 claims of your own cases?
16 A. And sometimes -- well, often the cases of
17 others in my law firm and occasionally the cases of
18 lawyers outside my law firm who seek my opinion or my
19 firm's opinions with regard to the value of their cases.
20 Q. So, other than evaluating the claims that you
21 just described, your own cases, others in the firm,
22 other lawyers and so forth, have you done any other
23 research during your career that supports your purported
24 expertise?
25 A. The study that I have described to you
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
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Page 28
1 earlier.
2 Q. Other than what we have talked about here
3 today?
4 A. I can't think of anything else that would
5 directly be relevant. Something else may come to mind.
6 If it does, I will let you know. That's all I can think
7 of right now.
8 Q. Okay. You referred to the process of
9 evaluating a punitive damages claim.
10 A. Yes, sir.
11 Q. Is that a process that you developed or was
12 that developed by some other punitive damages expert?
13 A. It is a process that has developed over the
14 course of my personal practice. That is, I haven't
15 taken somebody else's evaluative process and adopted
16 that as my own.
17 Q. And is your process an accepted process in the
18 legal industry for evaluating the value of punitive
19 damages claims?
20 A. I think the answer to that question is yes.
21 Q. Okay. And how do you know that it's -- would
22 you say it's widely accepted in the legal industry as a
23 process for evaluating the value of punitive damages
24 claims?
25 A. Yes.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
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Page 29
1 Q. Has your method been published?
2 A. It has been.
3 Q. Where has this been published?
4 A. It has been published in court opinions of
5 which I am aware. It has been published in legal
6 treatises of which I am aware, and it has been published
7 in the CLE materials that I, myself, have written in
8 connection with lectures in this area that I have given.
9 Q. Okay. So, there is a court opinion out there
10 that discusses your internal process for evaluating the
11 value of punitive damages claims?
12 A. There is a court opinion out there that
13 addresses the issue of how punitive damages should be
14 evaluated, yes.
15 Q. And let's make sure we are talking, using the
16 same words here. How a punitive damages claim should be
17 evaluated versus how you -- how one values a purported
18 punitive damages claim. Are we talking about the same
19 thing?
20 A. That's a distinction that I don't understand.
21 Maybe I can be helpful to you here so we don't spend a
22 lot of time mis-communicating.
23 Q. That would be great.
24 A. There are authorities that identify
25 aggravating and mitigating circumstances that are
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130444
Page 30
1 appropriately taken into consideration in assessing the
2 amount of punitive damages necessary to serve the dual
3 purpose of punitive damages recognized in the State of
4 Florida, punishment and deterrence. The case that most
5 specifically addresses those factors is the
6 Johns-Manville case, which is included in the materials
7 that have been provided to you.
8 Q. Just so we are clear, when we are talking
9 about the publication of your process to evaluate
10 punitive damages, do these cases say this is how Jack
11 Scarola does it and we think that that's the proper way
12 to do it, or do these cases discuss different factors
13 that a court should consider in evaluating punitive
14 damages and you have adopted parts of that in your
15 process?
16 A. There is no published opinion that attributes
17 this process to me. There are published opinions that
18 identify appropriate factors to be taken into
19 consideration by both judges and juries in determining
20 the appropriate amount of punitive damages necessary to
21 serve the dual purpose of punishment and deterrence.
22 Q. Are there any publications, other than the
23 court opinions, that discuss Jack Scarola's process,
24 your individual process that you have utilized in this
25 matter to evaluate or to place a value on the potential
OUELLETTE & MAULDIN COURT REPORTERS, INC.
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Page 31
1 punitive damages claims in the underlying cases?
2 A. Except for my own materials, which obviously
3 include my name, I am not aware and would be very
4 surprised to find any case or treatise or other
5 publication that attributes the identification of
6 aggravating and mitigating circumstances to Jack
7 Scarola. This is not something that I authored, except
8 to the extent that it's incorporated in CLE outlines.
9 It is a recognition of the appropriateness of
10 specifically identified factors in both cases and
11 treatises to asses the appropriate amount of punitive
12 damages in order to serve the dual function of
13 punishment and deterrence.
14 Q. Punishment and deterrence, are those the
15 purposes of punitive damages under Florida law?
16 A. Yes, sir.
17 Q. Are punitive damages under Florida law meant
18 to compensate a plaintiff?
19 A. They are not, except to a limited extent that
20 is recognized in the case law, and that is that there is
21 a recognition in the case law that the plaintiff who
22 undertakes the prosecution of a punitive damage claim is
23 serving a function in effect as a public prosecutor to
24 preserve the integrity of the judicial system and to
25 preserve appropriate standards within, in this context,
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130446
Page 32
1 the business community. So, to motivate individuals to
2 undertake the difficult task of prosecuting a punitive
3 damage claim, one of the factors that is taken into
4 consideration are the costs involved in prosecuting that
5 claim.
6 Q. And what case ---
7 A. So punitive damages help to compensate the
8 plaintiff for undertaking that broader societal purpose.
9 Q. To recoup the costs incurred in protecting
10 society's or the state's interest in pursuing punitive
11 damages?
12 A. Yes, sir.
13 Q. And what case do you believe best describes
14 that function?
15 A. Well, I know it's described in more than one
16 case, but the one that comes to mind immediately is
17 Johns-Manville.
18 Q. What is your process for placing a value on
19 potential punitive damages claims?
20 A. It is to review the evidence in the light of
21 recognized aggravating and mitigating circumstances, to
22 assess the way in which those factors impact upon the
23 intended purpose of punitive damages to punish the
24 wrongdoer and to deter others similarly situated from
25 engaging in the same kind of wrongdoing, to review any
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
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Page 33
1 statutory limitations that might apply and to consider
2 any constitutional limitations that might apply in
3 arriving at an opinion as to what I believe the range of
4 punitive damage value of a case is likely to be
5 I would also take into consideration the
6 extent to which the same or similar circumstances have
7 already been assessed by an independent finder of fact.
8 Q. Let me make sure I got all of this down. It
9 seems like there is several different factors. First,
10 the evidence with respect to the claims at issue. You
11 would review that. You would review any statutory
12 limitations.
13 A. May I interrupt for just a moment?
14 Q. Yes, sir.
15 A. Because the evidence I am reviewing is
16 particularly that evidence that relates to the
17 aggravating and mitigating circumstances with respect to
18 punitive damages. I would not necessarily find it
19 necessary to review all of the evidence with respect to
20 a given matter and have not undertaken to attempt to
21 review all of the evidence with regard to this case.
22 Q. Would you review any of the evidence to
23 ascertain the viability of the underlying claims?
24 A. Certainly to some extent, yes, and I need in
25 circumstances such as this to make some assumptions with
OUELLETTE & MA LDIN COURRT REPORTERS, INC.
EFTA01130448
Page 34
1 regard to the viability of the underlying case and have
2 done so here. Obviously, if this is were my own case, I
3 would be assessing all of the evidence with regard to
4 the viability of the underlying case.
5 Q. You said you had made certain assumptions in
6 this matter concerning the viability of the underlying
7 claims. Correct?
8 A. That is correct.
9 Q. What assumptions have you made?
10 A. That the underlying claims are accurately
11 described in the complaints that I have reviewed, that
12 they are accurately described in court orders that I
13 have reviewed, that they are accurately described in
14 pleadings and memoranda that I have reviewed, and to a
15 limited extent that they have been accurately described
16 in verbal communications that I have had with both
17 Mr. Moskowitz and Mr. Scherer.
18 Q. So, for your analysis of the viability of the
19 underlying claims in this matter, are you accepting all
20 of plaintiffs' allegations to be true?
21 A. Yes. I have accepted the allegations in the
22 complaint to be true to the extent that any particular
23 allegation was or is shown not to be accurate that may
24 or may not affect my opinion, and that's something that
25 I would need to view in the context of the overall case.
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA01130449
Pagc 35
1 Q. And are you accepting all of the
2 representations from Mr. Scherer and Mr. Moskowitz as
3 true with respect to the underlying facts?
4 A. They have
DataSet-10
Unknown
1 pages
From: "Earl Nemser" <
To:c
Subject: RE: (no subject)
Date: Tue, 28 May 2013 13:26:21 +0000
Hi Jonathan,
Ordinarily there are no depositions in Finra arbitrations, but there will be live testimony at the hearing. I know David
Hoffner. He used to work at my law firm. He is a pretty good lawyer. Very tenacious.
Best.
Earl
From: (mallto
Sent Tuesday, May 28, 2013 6:56 AM
To:
Subject: (no subject)
Earl if i bring a finra case against Elkman will i spend days in deposition thanks Jonathan
EFTA00657713
DataSet-10
Unknown
2 pages
IN THE COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT, IN AND FOR PALM BEACH
COUNTY, FLORIDA
E.N.,
CASE NO. 502008CA028058,OOO(MB AD
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEO DEPOSITION
To: See Service List below
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition via video ot:
DEPONENT DATE & TIME LOCATION OF DEPOSITION
L.M. Friday Burman Craton Lanier & Coleman,
do Brad Edwards, Esq. October 16, 2009 LLC
Rothstein Rosenfeldt Adler @ 10:00 aan. 303 Banyan Blvd, Suite #400
401 East Las Olas Boulevard West Palm Beach, FL 33401
Suite 1650
Fort Lauderdale, FL 33301
upon oral examination, before Prose Court Reporting Agency, Inc., a Notary Public, or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken for the
purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes
of Rules of Court.
I HEREBY CERTIFY that a true copy of the foregoing was sent by electronic mail (e-mail) and U.S.
Mail to the addresses listed on the below Service List on this It day of August. 2009.
BURMAN, CRITTON, LUTHER & COLEMAN, LLP
303 Banyan Blvd., Suite 400
Mich, F1.33401
Fax
By:
Robert . Critton, Jr.
Flori Bar #224162
Michael J. Pike
Florida Bar #617296
(Counselfor Defendant Jeffrey Epstein)
EFTA00728283
E.W. v. Epstein
Page 2
E.W. v. Epstein
Service List
Brad Edwards, Esq. Jack Alan Goldberger, Esq.
Brad Edwards and Associates, LLC Atterbury Goldberger & Weiss, P.A.
2028 Harrison Street 250 Australian Avenue South
Suite 202 Suite 1400
Hollywood, FL 33020 West Palm Beac FL 33401-5012
Phone Fax:
Fax Co-Counselfor Defendant Jeffrey Epstein
Counselfor Plaintiff'
Jay Howell, Esq.
Jay Howell & Associates, P.A.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Phone
ax
Co-counsel for Plaintiff
EFTA00728284
DataSet-10
Unknown
1 pages
IN THE CIRCUIT COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM BFACH
COUNTY, FLORIDA
CASE NO.: 2006CF009454AXX
STATE OF FLORIDA
vs. NOTICE OF DEPOSITION r:
JEFFREY EPSTEIN, utTE OF FLORIDA • PALM BEACH C.. ...1 2 r-1
-c-
Defendant. I hereby certify that the
foregoing le a twe copy
°It crd my Mce. n
i :2
°21 P
C;
TO: Lanna Belohlavek, Esquire ' :depositions in the State of Florida, the
Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to
wit:
Such oral examination will continue from day to day until completed. You are hereby notified to
phone in and take part in said examination as you may be advised, and as shall be fit and proper.
This deposition is being taken for the purposes of discovery, for use as primary evidence or for
such other purposes as are permitted under the applicable Statutes or Rules of Court
I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been
furnished to the above named addressee and Michael IL Tein, Esquire, 3059 Grand Avenue,
Suite 340, Coconut Grove, Florida 33133 by via fax & mail this 25th day of March, 2008.
ATTERBURY, GOLDBERGER, & WEISS, P.A.
250 Australian Avenue South, Suite 1400
We t Palm Beach, Florida 33401
J A GOLDBERGER, ESQUIRE
ti
Fl da Bar No. 262013
MM15-STATE CASE-000186
EFTA_00049315
EFTA01250598
DataSet-10
Unknown
2 pages
IN THE CIRCUIT COURT FOR THE
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
FILE NO. 502008CP003626XXXXMB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S CROSS NOTICE OF DEPOSITION OF DETECTIVE JOSEPH RECARY
PLEASE TAKE NOTICE that plaintiff, E.W., will take the deposition by oral
examination, of the persons named below, at the time, on the date, at the hour of the place
indicated:
NAME DATE AND PLACE OF TAKING DEPOSITON
TIME
Det. Joseph Recarey February 25, Prose Court Reporting
do Joanne M. O'Connor, Esq. 2010 © 9:30 AM One Clearlake Centre
Jones, Foster, Johnson & 250 Australian Avenue South
Stubbs, P.A. West Palm Beach, FL 33401
505 S. Flagler Drive, #1100
West Palm Beach, FL 33401
upon oral examination before Prose Court Reporting, Notary Public, or any other notary
public or officer authorized by law to take depositions in the State of Florida. The oral
examination will continue from day to day until completed. The depositions are being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted
1
EFTA00725397
under the Rules of Court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
U.S. Mail and email on February ( ck , 2010 to: Robert D. Critton, Jr., Esq., Burman, Critton,
et al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401; Jay Howell, Esq.,
Jay Howell & Assoc., 644 Cesery Boulevard, Suite 250, Jacksonville, FL 32211; and Jack
Alan Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400.
West Palm Beach, FL 33401.
Farmer, Jaffe, Weissing,
Edwards, Fistos & Lehrman,
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954) 524-2820
(954) 524-2822 fax
[email protected]
By:
RADLEY J. EDWARDS
Florida Bar No.: 542075
2
EFTA00725398
DataSet-10
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
on Thursday, September 3, 2009, at 10:00 a.m., at:
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this jzgday of August, 2009 to all those on the
attached Service List.
1
EFTA00738468
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel: (954) 522-3456
Fax: (954) 527-8663
Email: bedwards rra-law.com
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reporters
EFTA00738469
DataSet-10
Unknown
3 pages
From: Martin Weinberg
To: "jeffrey E." [email protected]>
Cc: Martin Weinberg
Subject: Re: ATTORNEY-CLIENT PRIVILEGE
Date: Thu, 07 Apr 2016 12:47:23 +0000
Yes re Simpson
MTQ unlikely to totally stop deposition - more to limit it, perhaps protective order re video dissemination
I could discuss venue, time if we want to negotiate date, place otherwise they could serve you in fla or vi
Yes, risk of transfer to ny from boston but i can blame my own packed schedule if Sigrid agrees to boston which
is unlikely
Sent from my iPhone
On Apr 7, 2016, at 6:06 AM, "jeffrey E." leevacation®gmail.com> wrote:
> cant use that as i am not registered in those places.. what does the motion look like? should we just do it in
sdny so the judge doesnt think we are playing cute..
> spoke to alan he told me two weeks ago that all was setllted and i should send him the money, i did. he told me
only yesterday that there are delays but only two more days ( I had been clear that AAA (SRI
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