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IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051XXXXMB
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO: '
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 7, 2009 at 10:00 a.m., at _ Esquire Court Reporters, 515
North Flagler Drive, West Palm Beach, FL 33401 for the taking of your deposition in
this action and to have with you at that time and place the following:
All original flight logs from January, 1998 through present for any and all
aircraft/airplanes/jets which you piloted or co-piloted that were owned or
controlled by Jeffrey Epstein or Ghislaine Maxwell.
If you fail to appear, you may be in contempt of court. You are subpoenaed
to appear by the following attorneys and unless excused from this Subpoena by these
attorneys or the Court you shall respond to this Subpoena as directed.
DATED on August2472009.
1
EFTA00730309
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
Florida Bar No.: 542075
2
EFTA00730310
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INDEX
DISCOVERY CD
(INCLUDES RFA, RTP, ROGS)
1
2
3
4
5
6
7
8
9
1
1
1
1
MEDICALS & INVESTIGATION CD
(INCLUDES MEDICAL RECORDS AND INVESTIGATO
R REPORTS)
1
2
3
4
5
6
7
8
9
1
1
1
1
EFTA00809138
14
15
16
MISCELLANEOUS CD
1. Affidavits / Declarations
2. Hyperion Flight Logs
3. JE Phone Records Summaries
4. Josefsberg Correspondence
5. Josefsberg Billing
6. Maxwell (actually additional affidavits / declarations)
7. Settlement Agreement(s)
8. State Attorney File
9. Town of Palm Beach Police Dept. File
10. USA() Correspondence from Kirkland Ellis
11.Villafana Correspondence RE: document production
TRANSCRIPTS CD
(DEPOSITION AND HEARING)
1. Depositions (listed by date and name within)
- Banasiak, Janusz
- Brewster, Clint
- Dr. April Kassover
Dr. Karroum
- Dr. Kathy Sloan
Dr. Reed
Edwards, Brad
- Epstein, Jeffrey
111111
EFTA00809139
- Kliman Records Custodian
- IMi t
- Orezzoli. Rocky
- Randee Speciale, MS
- Rodri uez, Alfredo
- Ruperto, Ricky
- Tonoroglu, Ibraham
- Vanover, Justin
1=1
2. Hearings (listed by date and Judge within folder)
PLEADINGS CD
- State
2 - State
3 v. E stein — Federal
4. Doe #1 ) — State
5. Doe #2 — Federal — Consolidated Pleadings
6. Doe II - State
- State
- Appellate
- State
- Appellate
**** ADDITIONAL DOCUMENTS ON INDIVIDUAL CDs ARE AS FOLLOWS AND
GROUPED ACCORDINGLY:
TRANSCRIPTS
Depositions
1. Deposition of (I and II)
2. Deposition of Larry Morrison (I and II)
3. Deposition of Larry Visoski
EFTA00809140
4. Deposition of Mark Epstein
5. Deposition of
6. Deposition of Michael Reiter (I and II)
7. Deposition of JE - 05.07.2009
Hearings
1. Hearing — Judge French — Motion to Dismiss
2. Hearing — Judge Hafele — Motion to Add Punitive Damages
3. Hearing — Judge Hafele - Motion for Protective Order
4. Hearing - Judge Hafele - on seven (7) Motions
VIDEOS
Depositions
10. Epstein, Jeffrey (numerous — as indicated by date on CD)
12. Tonaroglu, Ibraham
EFTA00809141
IMEs and Expert Reports
=
4. All Does 2-7 Records and Interview Transcripts with Dr. Gilbert Kliman
(Plaintiff Retained Expert)
5. All Dr. Hall Reports (JE Retained Expert)
Investigative / Miscellaneous
1. Video Surveillance (on CDs identified by date)
Or
2. Demon Cycle Photos of - (RE: Depo of Owner Thomas Steinbacher)
3. Files — contains investigative files identified by named folders)
4 Walkthrough Video
5. Property Inspection Video
6. News Footage 09/10/2008
7 Pleadings and Documents
8. Josefsberg Bills
EFTA00809142
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From: ==. >
To: Larry Visoski Larry
Subject: Re: plans?
Date: Sun, 24 Aug 2014 15:08:41 +0000
ok, thanks
On Aug 24, 2014, at 11:07 AM, Larry Visoski wrote:
> He just sent me a message, he's thinking of Paris Wednesday night at 10 PM
> Not confirmed he said thinking
> Sent from my iPhone
>> On Aug 24, 2014, at 11:05 AM, wrote:
>>
>> Hi Larry...thanks for the flight logs...Has Jeffrey said anything re his travel plans this
week? NY? Paris?
>>
>> :)
EFTA00364026
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From: Richard Kahn
To: Lesley Groff
Subject: Re:
Date: Thu, 13 Mar 2014 13:29:44 +0000
thanks
Richard Kahn
HBRK Associates Inc.
575 Lexington Avenue, 4th Floor,
New York, New York 10022
tel
fax
cel
On Mar 13, 2014, at 9:29 AM, Lesley Groff < wrote:
I'll research for you
On Mar 13, 2014, at 9:24 AM, Richard Kahn wrote:
if you have access to old emails can you please forward me email larry sent on may 25th 2013 with flight logs
thanks
Richard Kahn
HBRK Associates Inc.
575 Lexington Avenue, 4th Floor,
New York. New York 10022
tel
fax
cel
EFTA00372989
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FBI withheld `thousands of pages' of
Jeffrey Epstein docs, Pam Bondi says —
and she's demanding they be turned
over
By Josh Christenson
Published Feb. 27, 2025, 3:28 p.m. ET
476 Comments
00:00
00:54
WASHINGTON — Attorney General Pam Bondi revealed Thursday that "thousands of
pages" of documents in the FBI's investigation into the sex trafficker Jeffrey Epstein
were withheld from her.
And she's demanding that they be turned over by Friday morning.
Bondi 59 disclosed in a letter to FBI Director Kash Patel a tipster said that all but
"approximately 200 pages of documents" were still being kept secret at the FBI's office
in New York — despite her repeated requests for the "full" Epstein files.
EFTA00173333
7
Attorney General Pam Bondi revealed that the New York FBI office withheld thousands
of pages in documents about the Jeffrey Epstein investigation from her.
AP Photo/Jose Luis Magana
The initial batch included flight logs, phone numbers and the names of victims, but a
source in the FBI's New York office reached out and said that hundreds additional
documents were not included.
AdChoices [I=.
The video player is currently playing an ad. You can skip the ad in 5 sec with a mouse or
keyboard
"By 8:00 a.m. tomorrow, February 28, the FBI will deliver the full and complete Epstein
files to my office, including all records, documents, audio and video recordings, and
materials related to Jeffrey Epstein and his clients, regardless of how such information
was obtained," Bondi said.
"There will be no withholdings or limitations to my or your access," she vowed to Patel.
Rep. Andy Ogles (R-Tenn.) has floated a bill to prevent non-public records on Epstein
housed at the Department of Justice from being destroyed, according to a copy of a
letter obtained by The Post.
EFTA00173334
7
Bondi said in a letter to FBI Director Kash Patel that all but 200 documents on Epstein
are being kept in secret files in New York.
REUTERS
EFTA00173335
7
The Jacob K. Javits Federal Building in Manhattan — where Bondi claims additional
Epstein documents are being kept.
SeanPavonePhoto — stock.adobe.com
Ogles, 53, wrote to Bondi on Wednesday, announcing that he was "drafting legislation
entitle the Preventing Epstein Documentation Obliteration Act, or the PEDO Act"
following "reports that certain FBI agents are allegedly attempting to destroy critical
records."
"Should you encounter any statutory barriers to the expeditious public release of Jeffrey
Epstein's client list or other pertinent information related to his activities — to include
EFTA00173336
circumstances in which any such documentation is housed in other federal agencies -
I stand ready to assist," he said.
"Our constituents deserve nothing less than radical transparency in matters implicating
the integrity of our justice system," he added in the missive, which was first reported by
Fox News.
7
Rep. Andy Ogles (R-Tenn.) has floated a bill to prevent non-public records on sex
trafficker Jeffrey Epstein housed at the Department of Justice from being destroyed,
according to a copy of a letter obtained by The Post.
CQ-Roll Call, Inc via Getty Images
A former FBI special agent had suggested the Epstein files could be among documents
during a recent interview on the conservative influencer Benny Johnson's podcast.
"There are FBI servers," said ex-agent-turned-whistleblower Garret O'Boyle "and
people inside the FBI have been working night and day to destroy files on these
servers."
EFTA00173337
"No idea on what it is — I can only speculate — but you mentioned the Epstein list," he
added. "I'd imagine it's cases like that."
The FBI currently has hundreds of Epstein files available to the public on its website, but
The Post previously scooped that the Justice Department was preparing to release 100
pages of the notorious criminal's personal address book on Thursday, according to a
source who reviewed the files.
7
The DOJ is preparing the release Epstein's pesonal address book.
Patrick McMullan via Getty Images
EFTA00173338
Bondi had hinted on Fox News "Jesse Wafters Primetime" that the DOJ was going to
release "some Epstein information," while adding the fact that details of the financier's
abuse of more than 250 victims "will make you sick."
Conservative influencers were received at the White House and presented with "Phase
1" of the Epstein files release, emerging from the West Wing Thursday afternoon to
brandish the binders at the press without immediately disclosing any details.
The Mon
Transparent filminS-- att.
stestator of Or, ,
Ihnsald r !pop
The Justice Department is releasing 100 pages of Epstein's personal address book on
Thursday, according to a source who reviewed the files.
AFP via Getty Images
Ogles in his letter to Bondi also claimed a "decades-long obfuscation campaign" had
withheld full details on investigations into the assassinations of President John F.
Kennedy, Dr. Martin Luther King Jr. and Attorney General Robert F. Kennedy.
EFTA00173339
The effect of that "has clearly marginalized trust in our institutions and has contributed
to all sorts of alternative theories and motivations regarding the deaths of these men,"
he said.
Another Tennessee lawmaker has also pushed for the full release of the Epstein files.
7
Conservative influencers were received at the White House and presented with "Phase
1" of the Epstein files release.
REUTERS
"For years, my efforts to crack the Epstein trafficking ring wide open have been
stonewalled by Democrats at every turn," Sen. Marsha Blackburn (R-Tenn.) posted
Monday on X.
"This will change under [FBI Director Kash Patel]. I just sent him a letter asking for the
complete & unredacted Epstein files."
476
EFTA00173340
What do you think? Post a comment.
In his confirmation hearing, Patel committed to Blackburn that he would "do everything"
to reveal the "full weight" of "what happened" in Epstein's child sex trafficking ring.
The FBI did not immediately respond to a request for comment.
EFTA00173341
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From: Tyler Shears
To: Jeffrey Epstein ,
Subject: Fwd: Google Alert - Jeffrey Epstein
Date: Thu, 20 Mar 2014 18:19:46 +0000
Looks like Priceline Director made a bad move today and has the same name - this works to our advantage.
Pushing on this story now.
Forwarded message
From: Google Alerts
Date: Thu, Mar 20, 2014 at 2:04 PM
Subject: Google Alert - Jeffrey Epstein
To:
Jeffrey Epstein
As-it-happens update • March 20, 2014
NEWS
Insider Selling: Jeffrey Epstein Sells 2000 Shares of Priceline.com Stock
(PCLN)
Ticker Report
Priceline.com logo Priceline.com (NASDAQ:PCLN) Director Jeffrey Epstein unloaded 2.000 shares of the
stock on the open market in a transaction ...
G F T
Bill Clinton links to Prince Andrew's billionaire friend Jeffrey
Epstein
Daily Mail
Newly disclosed flight logs show that between 2002 and 2005 the former US President
travelled around the world courtesy of Jeffrey Epstein while his ... Daily Mail
G F T
Edit this alert
You have received this email because you have subscribed to Google Alerts.
Unsubscribe I View all your alerts
; iARSS Receive this alert as RSS feed
Send Feedback
EFTA00717179
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IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
L.M., )
)
Plaintiff, ) CASE NO.: 502008CA028051)00Cflight logs from January, 1998 through present for any and all
aircraft/airplanes/jets which you piloted or co-piloted that were owned or
controlled by Jeffrey Epstein or Ghislaine Maxwell.
If you fail to appear, you may be in contempt of court. You are subpoenaed
to appear by the following attorneys and unless excused from this Subpoena by these
attorneys or the Court you shall respond to this Subpoena as directed.
DATED on August21, 2009.
EFTA00774015
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
I Florida 33301
EFTA00774016
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1 pages
To:
From: Larry Visoski
Sent: Sun 8/24/2014 3:07:27 PM
Subject: Re: plans?
He just sent me a message, he's thinking of Paris Wednesday night at 10 PM Not
confirmed he said thinking
Sent from my iPhone
> On Aug 24, 2014, at 11:05 AM, wrote:
> Hi Larry—thanks for the flight logs—Has Jeffrey said anything re his travel
plans this week? NY? Paris?
> :
EFTA_R1_00702662
EFTA02098423
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IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
)
)
Plaintiff, ) CASE NO.: 502008CA028051)00Cflight logs from January, 1998 through present for any and all
aircraft/airplanes/jets which you piloted or co-piloted that were owned or
controlled by Jeffrey Epstein or Ghislaine Maxwell.
If you fail to appear, you may be in contempt of court. You are subpoenaed
to appear by the following attorneys and unless excused from this Subpoena by these
attorneys or the Court you shall respond to this Subpoena as directed.
DATED on August21, 2009.
EFTA00730325
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
• • 75
EFTA00730326
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From: Lesley Groff
To: "George Delson & Associates Delson, George"
Subject: Jeffrey Epstein
Date: Mon, 25 Apr 2011 14:36:07 +0000
Hi Mary Ellen. Can you please ask George to count up all of Jeffrey's days? I faxed you
over his most recent flight logs. He left this past Saturday April 23, 2011 for the island
and is still there now.
I will get the monthly calendars faxed to the office to help him out as well.
Please reply back and let me know when we might recieve the information...
Thanks, Lesley
EFTA00434871
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To: Lesley Grof
From:
Sent: Thur 3/13/2014 1:29:44 PM
Subject: Re:
thanks
Richard Kahn
On Mar 13, 2014, at 9:29 AM wrote:
I'll research for you
On Mar 13, 2014, at 9:24 AM, Richard Kahn wrote:
if you have access to old cmails can you please fonvard me email tarry
sent on may 25th 2013 with flight logs
thanks
Richard Kahn
HBRK Associates Inc.
EFTA_R1_00732541
EFTA02111250
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From:
To: '
Subject: [EXTERNAL EMAIL] - FBI Daily News Briefing - July 9, 2025
Date: Wed, 09 Jul 2025 10:10:10 +0000
Importance: Normal
EFTA00163550
EFTA00163551
U.S. Justice Department Scrambles to Defend Its About-Face on Release of Epstein Files
Reuters (07/08, Lynch, Sullivan) reported that President Trump's Justice Department scrambled on Tuesday to
answer questions after its leadership concluded there was no evidence to support a number of long-held
conspiracy theories about the death of accused sex trafficker Jeffrey Epstein and his alleged clientele. Conservative
influencers from Laura Loomer to Elon Musk have criticized AG Bondi and Director Patel for their findings, which
came months after AG Bondi pledged to reveal major revelations about Epstein, including "a lot of names" and "a
lot of flight logs." "It's sitting on my desk right now to review," AG Bondi told Fox News in February when she was
asked if the Justice Department would be releasing Epstein's client list. On Tuesday at the White House, AG Bondi
walked that comment back, telling reporters that she was referring to the entire Epstein "file" along with other files
pertaining to the assassinations of John F. Kennedy and Martin Luther King, Jr. "That's what I meant by that," she
EFTA00163552
said. She added that the many of the videos in the Epstein investigative file "turned out to be child porn." This
material, she added, is "never going to be released. Never going to see the light of day." The article added that the
Justice Department's memo, released on Monday, concluded that after reviewing more than 300 gigabytes of data,
there was "no incriminating client list," nor was there any evidence that Epstein may have blackmailed prominent
people. The memo also confirmed prior findings by the FBI, which concluded that Epstein died by suicide in his jail
cell while awaiting trial, and not as a result of a criminal act such as murder. A subsequent report by the Justice
Department's inspector general later found that the Bureau of Prisons employees who were tasked with guarding
Epstein failed to search his cell or check on him in the hours before his suicide. The article highlighted that Director
Patel and Deputy Director Bongino both previously made statements before working at the FBI about a so-called
client list and often suggested that the government was hiding information about Epstein from the American
public. Trump defended them in a Truth Social Post on Monday amid a backlash by his MAGA base, calling them the
"greatest law enforcement professionals." He expressed annoyance when reporters asked him questions about
Epstein on Tuesday at the White House during a cabinet meeting, saying, "Are you still talking about Jeffrey
Epstein?" Forbes (07/08, Dorn) reported that Deputy Director Bongino told his podcast audience in 2023: "Listen,
that Jeffrey Epstein story is a big deal, please do not let that story go. Keep your eye on this" and questioned "what
the hell are they hiding with Jeffrey Epstein?" without specifying who "they" are. Deputy Director Bongino also
proliferated the conspiracy theory that Epstein is "an intelligence asset for people in the Middle East," during a
2023 appearance on right-wing podcaster Tim Pool's "Timcast IRL," alleging an unnamed Fox reporter shared the
information with him. According to the article, Director Patel suggested to right-wing podcaster Benny Johnson in
December 2023 Congress was blocking the purported list "because of who's on that list," telling Johnson "you don't
think that Bill Gates is lobbying Congress night and day to prevent the disclosure of that list?" while deriding House
Republicans for allegedly failing to release the list: "put on your big boy pants and let us know who the pedophiles
are." In November, days before Trump was elected, Director Patel again appeared on the Benny Johnson podcast
and said Trump is going to "maybe" release the "Epstein list." The article highlighted that President of the
conservative Judicial Watch movement Tom Fitton told Steve Bannon on Monday, "I don't even think the Biden
administration would have written anything like this. I just don't think they could have thought they could get away
with it. And I gotta wonder what is going on at the leadership of the Justice Department and the FBI." Additional
reporting on the story was provided by ABC News (07/08, Steakin), Axios (07/08, Scribner), BBC (07/08,
Debusmann Jr.), Daily Beast (07/08, Palmer), Fox News (07/08, Colton), The Hill (07/08, Waldvogel), NBC News
(07/08, Collier, O'Donnell, et al.), Newsweek (07/08, Mordowanec), New York Post (07/08, Kaplan), NewsNation
(07/08, Djordjevic), New York Times (07/08, Thrush, Thompson), Politico (07/08, Svirnovskiy), USA Today (07/08,
Ramaswamy), Wall Street Journal (07/08, Gurman), Washington Examiner (07/08, Lim), Washington Post (07/08,
Paybarah), and the Washington Times (07/08, Mordock).
EFTA00163553
EFTA00163554
EFTA00163555
EFTA00163556
EFTA00163557
EFTA00163558
EFTA00163559
EFTA00163560
EFTA00163561
EFTA00163562
EFTA00163563
EFTA00163564
EFTA00163565
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To: Larry Visoski Larry
From: Soimilif
Sent Sun 8/24/2014 3:08:41 PM
Subject: Re: plans?
ok, thanks
On Aug 24, 2014, at 11:07 AM, Larry Visoski wrote:
> He just sent me a message, he's thinking of Paris Wednesday night at 10 PM
> Not confirmed he said thinking
> Sent from my iPhone
» On Aug 24, 2014, at 11:05 AM, wrote:
>> Hi Larry-thanks for the flight logs-Has Jeffrey said anything re his travel
plans this week? NY? Paris?
» :)
EFTA_R1_00702703
EFTA02098444
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From: Brad Edwards
Sent: Friday, April 6, 2018 4:15 PM
To: jeffrey E.
Subject: RE: Re:
I had a feeling you would renege...again. The bet very clearly — Clinton was traveling on your plane at the same time you
were paying for VR to travel to Thailand.
Brad Edwards
Board Certified Trial Attorney
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Office I Facsimile:
I www.epllc.com
From: jeffrey E. [mailto:[email protected]
Sent: Friday, April 06, 2018 12:03 PM
To: Brad Edwards a>
Subject: Re:
Im sure you will be gracious and read the airports locatated on the flight logs !!!! these are all africa. not virginia AT
AL read Sept 27 . joburg capetown ghana. go to look at the aiport locators. on googel if you must. i expect the bill
:)
On Fri, Apr 6, 2018 at 5:49 PM, Brad Edwards > wrote:
CONFIDENTIAL SETTLEMENT DISCUSSIONS/NO PRIVILEGE WAIVER/PER YOUR REQUEST -
I expect a crisp, new bill. Your personalized message can say whatever you would like but it should include, "you
win!"
EFTA_R1_01597310
EFTA02481057
Brad Edwards
Board Certified Trial Attorney
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Office: Facsimile
please note
The information contained in this communication is confidential, may be attorney-client privileged, may constitute
inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use,
disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have
received this communication in error, please notify us immediately by return e-mail or by e-mail to
[email protected] , and destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
2
EFTA_R1_01597311
EFTA02481058
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From: BMG
Sent: Friday, March 20, 2015 3:50 AM
To: jeffrey E.
Cc: ZDC Office
Subject: Re: Ticketless Travel Passenger Itinerary
Thank you
Sent from my iP=one
On Mar 19, 2015, at 9:41 PM, jeffrey E. wrote:
Forwarded message ------_---
From: Southwest Airlines
<=r>
Lawrence maxwell Krauss is taking off soon!
chttps://www.southwest.com/flight/login> Check In Online
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flight/flight-status-select.html>
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Car Deals
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You're receiving th=s e-mail at the request of the purchaser, Passenger, or individual responsi=le for making the
travel arrangements below. This is a one-time communicati=n, and you will not receive further e-mails from Southwest
Airlines without=your consent.
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Passenger(s)
KRAUSS/LAWRENCE MAXWELL
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Date
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5
EFTA_R1_02015483
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From: Lesley Groff <1
To: George Delson
Subject: Re: Jeffrey Epstein
Date: Tue, 06 Sep 2011 13:56:19 +0000
terrific. thank you!
On Tue, Sep 6, 2011 at 9:52 AM, George Delson < wrote:
Lesley:
Yes I did receive them. Thanks.
Mary Ellen
US Treasury Department Circular 230 requires that we inform you that any federal tax advice contained in this
communication (including attachments) is not intended or written to be used, for the purpose of (i) avoiding
penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any
transactions or matter addressed herein.
--- On Fri, 9/2/11, Lesley Groff MIMIlle wrote:
> From:
> Subject: Jeffrey Epstein
> To: "George Delson & Associates Delson George"
> Date: Friday, September 2, 2011, 9:11 PM
> Just following up to make sure you
> rec'd the flight logs I sent over to you for Jeffrey...
> I called the office but there was no answer...
> Thank you, Lesley
EFTA00428807
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Bill Clinton, Naomi Campbell, others flew on Jeffrey Epstein's private jet, lawsuit reveals Page 1 of 2
PalmBeachDailyNews.com TUE SRISY SSW Print this page Close
Bill Clinton, Naomi Campbell, others flew on Jeffrey Epstein's private jet, lawsuit
reveals
By MICHELE DARGAN
DAILY NEWS STAFF WRITER
Updated: 2:59 p.m. Wednesday. April 21, 2010
Posted: 7:45 p.m. Tuesday, April 20. 2010
President Bill Clinton and Naomi Campbell are among the rich and famous who have flown aboard
convicted sex offender Jeffrey Epstein's private jet, according to flight logs from Epstein's private aircraft.
The flight logs from 2003-05 have been filed in one of the many civil lawsuits pending against the
billionaire money manager. Nearly two dozen young women have filed laws •iWstein — some
already settled — all alleging Epstein sexually abused them as minors at his n home.
Epstein, 57, was released from jail in July after serving 13 months of an 18-month state sentence for
soliciting a minor for prostitution and soliciting prostitution.
Attorney Brad Edwards, who represents Jane Doe and two other Epstein victims, filed the flight logs to
back up his case that Epstein traveled across state lines for the purpose of sexually abusing Jane Doe
and other victims.
"Epstein engaged in the act of trafficking minors across state or country borders for the purposes of sex
or prostitution between 2000 and the present. ... Epstein used the fact that he had transported other
minors across state and country borders for sexual purposes to help persuade Jane Doe to be sexually
abused by him. Epstein also asked Jane Doe to bring other gins to him. Epstein committed the same
sorts of acts against other minor girls," Edwards wrote in his pleading.
There are no allegations that anyone who with the
sexual abuse, other than Epstein employ according
to many of the teens, court documents an
The flight logs are for his Boeing 727 and Gulfstream jets.
Epstein, who has donated more than $100,000 over the years to candidates from the Democratic Party,
has also hosted several high-profile Democrats aboard his aircraft.
Clinton flew with Epstein from Nov. 4-9, 2003, to destinations that included Oslo, Norway; Russia, Hong
Kong, Shanghai and Beijing. On April 2, 2003, Campbell flew from the U.S. Virgin Islands to Brazil.
Failed Palm Beach mayoral candidate Gerry Goldsmith also was a guest on Epstein's plane, traveling
from Palm Beach International Airport to New Jersey's Teterboro Airport on Oct. 19, 2003. Former
Harvard president and current director of the White House's National Economic Council Larry Summers
flew more than once on Epstein's aircraft.
Also flying with Epstein during those years: Sandy Berger, who was the country's national security
adviser under Clinton; former Colombian President Andres Pastrana; and high-profile attorney Alan
DershowItz, who is part of Epstein's defense team.
Find this article at:
11
httpYMvrw.palmbeachdailynews.com/nevrs~atibbigher
http://vvynv.palmbeachdailynews.cominevis v n-Jeffrey-591119.html
Print this page Close
http://www.palmbeachdailynews.comMew-s/bill-clinton-naomi-campbell-others-flew-on-je... 4/23/2010
EFTA00611612
Bill Clinton, Naomi Campbell, others flew on Jeffrey Epstein's private jet, lawsuit reveals Page 2 of 2
http://www.palmbeachdailynews.c,orn/news/bill-clinton-naomi-campbell-others-flew-on-je... 4/23/2010
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To:
From: Jeffrey Epstein
Sent: Mon 3/12/2012 5:02:44 PM
Subject: Fwd: 2008 - 2010 Flying
2008-2010 Flyina.xlsx
Forwarded message
From: <
Date: Sat, Mar 10, 2012 at 12:44 PM
Subject: Re: 2008 - 2010 Flying
To: jecvacation(ii 2mail.com
Attached on an excel spreadsheet are the 2008 - 2010 trips that where flown prior to July 20th, 2010.
There appears to be five additional flights that occurred while I was on vacation for a total of 73 flights
during that time period. This flight information was obtained from my logbook and not the actual flight
logs. I will also try to send this information to you as an email without an attachment. I can also fax the
information to you if you need me to. Let me know if you need any information later than July 20, 2010.
In a message dated 3/10/2012 2:41:17 A.M. Eastern Standard Time, jeevacatiomthornail.com writes:
Can you send me the tdetsils on the trips
Sorry for all the typos .Sent from my iPhone
On Mar 9, 2012, at 11:17 PM, wrote:
Hi Jeffrey - Thanks for the kind words about being a loyal colleague. And yes you
were extra generous by continuing to pay me during the two years that you were not
able to fly when you wanted to. But, we did manage to fly 68 trips between July 2008
and July 20, 2010, most of which occurred between January and July of 2010. Thanks
for the approval to look for contract flying.
Also thank you so very much for paying for most of my daughter's college education.
She has been teaching deaf and hard of hearing kids now for almost two years now.
What a great gift it is for her to have no student loans and this would not have been
possible without your generosity. Thanks again for all of your support since 1991.
Best Wishes,
Dave
In a message dated 3/9/2012 5:10:20 P.M. Eastern Standard Time,
jeevacationewnail.com writes:
dave„ I understand your position„ I thought I was being extra generous by
continuing to pay you though i did not fly for two years. . you have been a loyal
colleague, I think it is time you and i come to a new understanding, and yes
you should be looking for contract flying as much as you can
On Fri, Mar 9, 2012 at 10:01 AM, < > wrote:
EFTA_R1_00224848
EFTA01840282
Hi Jeffrey,
In response to what does it mean lose nothing by putting it out there..
?TM? I have no idea what lose nothing by putting it out there"
means. I had never heard that phrase before I read Rich's email and
have certainly never said that phrase before. I do recall saying that 'the
worst case is Jeffrey can always say no if he does not agree." But I do
not recall saying lose nothing by putting it out there."
In response to why are training days full flying days, or any day at all?
Training days are required by the Federal Regulations as well as some
Insurance requirements. Sometimes the insurance requirement is more
demanding than the Federal Regulations. The days that I am in training
I have no other opportunity to earn additional income.
In response to aren't we paying? Yes you are paying for the training.
In response to how can flying be paid to dave???? When Darren
Indyke mentioned $1,000 per day for flying days, after he had reduced
my salary more than 68%, there was nothing discussed about the
possibility that I would not be flying on some of the trips. I feel this
situation needs to be addressed before we get to the point where I am
only flying 50 days or less per year, just so we can both agree on what is
fair. I have not been flying for anyone else other than two trips that
lasted a day each since I began working for you in 1991. If is
going to be flying instead of me on a trip, would it be alright if I looked
for Contract Flying jobs on those days?
My first concern is always safety of the passengers and my second
concern is complying with the Federal Regulations that we are required
to follow. If you have any further questions please let know.
Thanks,
Dave
In a message dated 3/8/2012 7:33:56 P.M. Eastern Standard Time,
jeevacat ion@qma il tom writes:
what does it mean lose nothing by putting it out there.. ??????why
are traini full flying days. or any day at all? arent we paying?
how can ys
flying be paid to dave????
On Thu, Mar 8, 2012 at 6:21 PM, Richard Kahn ‹ >
wrote:
Can you please help me understand your calculation of $109,500
you believe you are owed for 2011 (less the 50.000 already paid in
salary)
Some of the issues that i am having a difficult time understanding are the
following:
EFTA_R1_00224849
EFTA01840283
a) Billing of $1,000 per day when flew and you did not (11 days x 1000 =
11,000)
Please tell me something other than when we spoke last and you said that you
lose nothing by putting out there as JEE can always say no
b) Billing of $1,000 per day of flight training (8 days x 1000 = 18,000)
My understanding of your agreement after speaking with Darren Indyke was that
you were to be paid $1,000 per day for flying days and $500 per day
for repositioning days
Accordingly I am having a difficult time explaining the above to JE
I look forward to resolving this soon as i know you mentioned you wanted to be
paid in April 2012
Thank you
Richard Kahn
HBRK Associates Inc.
301 East 66th Street, Suite 1OF
065
The information contained in this communication is
confidential. may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
retum e-mail or by e-mail to jeevacationfamail.com and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
EFTA_R1_00224850
EFTA01840284
return e-mail or by e-mail to [email protected] and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA_R1_00224851
EFTA01840285
DataSet-10
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3 pages
To: [email protected]];
[email protected][[email protected]]
From: aiiaol.com
Sent: satM0/2012 4:44:27 PM
Subject: Re: 2008 - 2010 Flying
2008-2010 Flyinci xlsx
Attached on an excel spreadsheet are the 2008 - 2010 trips that where flown prior to July 20th, 2010.
There appears to be five additional flights that occurred while I was on vacation for a total of 73 flights during
that time period. This flight information was obtained from my logbook and not the actual flight logs. I will
also try to send this information to you as an email without an attachment. I can also fax the information to you
if you need me to. Let me know if you need any information later than July 20, 2010.
In a message dated 3/10/2012 2:41:17 A.M. Eastern Standard Time, [email protected] writes:
Can you send me the tdetsils on the trips
Sorry for all the typos .Sent from my iPhone
On Mar 9, 2012, at 11:17 PM, aol.com wrote:
Hi Jeffrey - Thanks for the kind words about being a loyal colleague. And yes you
were extra generous by continuing to pay me during the two years that you were not
able to fly when you wanted to. But, we did manage to fly 68 trips between July 2008
and July 20, 2010, most of which occurred between January and July of 2010. Thanks
for the approval to look for contract flying.
Also thank you so very much for paying for most of my daughters college education.
She has been teaching deaf and hard of hearing kids now for almost two years now.
What a great gift it is for her to have no student loans and this would not have been
possible without your generosity. Thanks again for all of your support since 1991.
Best Wishes,
Dave
In a message dated 3/9/2012 5:10:20 P.M. Eastem Standard Time,
jeevacationewnail.com writes:
dave„ I understand your position„ I thought I was being extra generous by
continuing to pay you though i did not fly for two years. . you have been a loyal
colleague, I think it is time you and i come to a new understanding, and yes
you should be looking for contract flying as much as you can
On Fri, Mar 9, 2012 at 10:01 AM, < eaol.com> wrote:
Hi Jeffrey,
In response to what does it mean lose nothing by putting it out there..
777, 77 I have no idea what lose nothing by putting it out there"
means. I had never heard that phrase before I read Rich's email and
have certainly never said that phrase before. I do recall saying that "the
worst case is Jeffrey can always say no if he does not agree." But I do
not recall saying lose nothing by putting it out there."
EFTA_R1_00534057
EFTA02026252
In response to why are training days full flying days, or any day at all?
Training days are required by the Federal Regulations as well as some
Insurance requirements. Sometimes the insurance requirement is more
demanding than the Federal Regulations. The days that I am in training
I have no other opportunity to earn additional income.
In response to aren't we paying? Yes you are paying for the training.
In response to how can nadia flying be paid to dave???? When Darren
Indyke mentioned $1,000 per day for flying days, after he had reduced
my salary more than 68%, there was nothing discussed about the
possibility that I would not be flying on some of the trips. I feel this
situation needs to be addressed before we get to the point where I am
only flying 50 days or less per year, just so we can both agree on what is
fair. I have not been flying for anyone else other than two trips that
lasted a day each since I began working for you in 1991. If Nadia is
going to be flying instead of me on a trip, would it be alright if I looked
for Contract Flying jobs on those days?
My first concern is always safety of the passengers and my second
concern is complying with the Federal Regulations that we are required
to follow. If you have any further questions please let know.
Thanks,
Dave
In a message dated 3/8/2012 7:33:56 P.M. Eastern Standard Time,
jeevacationOqmail.com writes:
what does it mean lose nothing by putting it out there.. 777, 77why
are training days full flying days, or any day at all? arent we paying?
how can nadia flying be paid to dave????
On Thu, Mar 8, 2012 at 6:21 PM, Richard Kahn
wrote:
Can you please help me understand your calculation of $109,500
you believe you are owed for 2011 (less the 50,000 already paid in
salary)
Some of the issues that i am having a difficult time understanding are the
following:
a) Billing of $1,000 per day when Nadia flew and you did not (11 days x 1000 =
11,000)
Please tell me something other than when we spoke last and you said that you
lose nothing by putting out there as JEE can always say no
b) Billing of $1,000 per day of flight training (8 days x 1000 = 18,000)
My understanding of your agreement after speaking with Darren Indyke was that
you were to be paid $1,000 per day for flying days and $500 per day
for repositioning days
EFTA_R1_00534058
EFTA02026253
Accordingly I am having a difficult time explaining the above to JE
I look forward to resolving this soon as i know you mentioned you wanted to be
paid in April 2012
Thank you
Richard Kahn
HBRK Associates Inc.
301 East 66th Street, Suite 1OF
New 10065
tel
fax
cell
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
retum e-mail or by e-mail to jeevacationewnail.com and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
retum e-mail or by e-mail to jeevacationearnail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA_R1_00534059
EFTA02026254
DataSet-10
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE, CASE NO. 08-CV-80893-MARRA/JOHNSON
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.
Defendant.
Related Cases:
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
PLAINTIFF'S MOTION TO FILE COMPOSITE EXHIBIT C TO PLAINTIFF'S
CORRECTED RESPONSE TO DEFENDANT'S MOTION FOR SUMMARY
JUDGMENT IDE 1401 UNDER SEAL
Plaintiff, Jane Doe, hereby moves this Court for an Order permitting Composite
Exhibit C of Plaintiffs Corrected Response to Defendant's Motion for Summary
Judgment (Corrected as to paragraph numbering) [DE 140] to be filed under seal.
At the deposition of one of Jeffrey Epstein's pilots David Rogers, flight logs were
produced pursuant to duces tecum. While there is no Court Order mandating the
confidentiality of these logs, there are names of numerous passengers that may or may
not wish to have their identities published. Therefore, in an abundance of caution, the
undersigned respectfully requests permission to file Exhibit C (flight logs) to Plaintiffs
Corrected Response to Defendant's Motion for Summary Judgment Under Seal.
DATED: April 13. 2010
EFTA00724066
CASE NO: 08-CV-80119-MARRA/JOHNSON
Respectfully Submitted,
radley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Laud 33301
Telephon
Facsimile
Florida Bar No.: 542075
E-mail:
and
Paul G. Cassell
Pro Hac Vice
332 S. 1400 E.
Salt Lake Ci
Telephone:
Facsimile:
E-Mail:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY a true and correct copy of the foregoing was sent via
CM/ECF and U.S. mail on April 13, 2010 to:
Robert D. Critton, Jr.
BURMAN, CRITTON, et al.
303 Banyan Boulevard, Suite 400
West Palm Beach, FL 33401
Jack Alan Goldberger, Esq.
Atterbury Goldberger et al.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401
Counsel for Jeffrey Epstein
radley J. Edwards
2
EFTA00724067