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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.: 502008CA028051XXXXMB
)
vs. )
)
JEFFREY EPSTEIN, )
)
Defendant. )
)
SUBPOENA DUCES TECUM
FOR VIDEOTAPED DEPOSITION
THE STATE OF FLORIDA:
TO: David Hart R ers
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
EFTA00774009
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale Florida 33301
Florida Bar No.:
2
EFTA00774010
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From: " '<
To: "Jeffrey E."
Subject:
Date: Wed, 04 Feb 2015 22:17:48 +0000
remember, I want to negotiate the movie rights....
i can see the beginning, a half angled shot of you on the plane looking out the window
with your arm resting on the maple veneer deep in thought ... OMG
http://www.dailymail.co.uldnews/article-2922773/Newly-released-flight-logs-reveal-time-trips-Bill-Clinton-
Harvard-law-professor-Alan-Dershowitz-took- edophile-Jeffrey-Epstein-s-Lolita-Express- rivate-jet-
anonymous-women.html
EFTA00865051
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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.
EFTA00172149
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.
EFTA00172150
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
EFTA00172151
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
EFTA00172152
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."
EFTA00172153
"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
EFTA00172154
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.
EFTA00172155
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
EFTA00172156
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.
EFTA00172157
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From: George Delson
To: Lesley Groff
Subject: Re: Jeffrey Epstein
Date: Fri, 11 Nov 2011 21:34:02 +0000
Thank you Lesley I did receive them. Have a good weekend.
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.
Original Message
From: Lesley Groff <
To: George Delson & Associates Delson George
Cc:
Sent: Thursday, November 10, 2011 2:18 PM
Subject: Jeffrey Epstein
Hi Mary Ellen...I just sent you flight logs for Jeffrey...I think you only need Oct. 30 and
Nov. 2, but just in case there are previous ones as well!
can you please confirm receipt?
Lesley
EFTA00424250
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2 pages
1.
(UHFOU0) Accurint:
• - DOB:
• SSN:
• Address:
• Phones:
I
(U//FOUO) Ejustice/NCIC
• Name (both) and DOB search: Negative
(U//FOUO) Open Source:
• A Thread from PAgenthadesl: "This #EpsteinAssociate is a former model at the Ford model
Agency. She's currently living in California f...1" (threader.aPP1
o Lists facebook and Linkedin: both inactive
• Virginia posted a tweet with her
F Tweet
Virginia Giuffre*
:VHSVT.iffia
is another Ghislaine Maxwell,
omen in #Epstein circle that
procured and participated. I'm outing her after going to
se and being yelled at. Victim blaming- not cool
Il MeTool. #EnoughlsEnough
#EpsteinDidNotKillHimself
y Umekubo
:tor of Child Development / Mom
c Partuxke. Califon, . 27S connectoons Contact in
0 0.0.1 Cah 00 0/1011 . Twittear few IDhnna
EFTA00155971
o Thread by Ostoneturnr. This thread will prove conclusively that Sill Clinton flew on
Epstein's plane [...] (twtext.com)
• Article shows_listed in flight logs
EFTA00155972
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From: Lesley Groff flight logs from recent flight :)
On Sep 23, 2013, at 1:24 PM, wrote:
> Hi,
> Any scoops if je is going to Paris? On airlines?
> Thx
> Larry
> Sent via BlackBerry by AT&T
EFTA00383183
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SOU
Master Case: wattle Cisr. No.:
c REQUEuI FOR ASSIGNMENT OF INVESTIGATOR
INVESTIGATIONi 200c.
From: BARBARA . PMRNS 7100
State . JEFYRICY EPSTE1' Jut.19. : Jeffrey Coltotth
Case: • 00BCF009381AMB -;-t-• PERSON UNDER AGE IR
PhOSTIT9TION
Request Fct: Suinpoena lotcez Tecus Servit:,
nn
Name: Larry Vlsoskt -optersilot to ‘J.t. :rev Epst:1n)
Lik42eAms Vtseen
To: Investigator
From: Supervisor Date:
You have been assigned the above matter. • completion of this assignment, sign, date,
and return this fess to your superviso: 'nth you: memo. if required. Completed
assignment, date.
Investigative Supervisoc
Date Completed: nc• ass:inmenr memo- tequiced, #212rits
a
•
0Subpoena(s)served: — rant seri/tit
ePosted:
IF U TO SERVE OR LOCATE COMPLETE NON SERVICE FORM
Other, completed
Investigate Date:
Mileage: Memo a tached:
09/12+2019 Page318 Agency to Agency Raquel: 19-411
CONF NTIAL
SDNY_GM_00330331
EFTA_00203057
EFTA02728868
Ia OF THE FIFTEENTH JUDICIAL
N AND I• DIVISION)
VS.
E et : •N
Visoski
DUCES TEMPI: Flight Logs May 1,
YOU ARE HERESY CCMMANDED and before the STATE ATTORNEY . Assistant,
and for . ,Im
Highway,
the
JErmnnY E EPSTEIN is the Defendant. You are cosaanded to bring with you the complete
. concerning any and
flights . Fr JEFFREY E. F,".11:1N. : to . ; .., with shl subpoena :
to ipt • t.
09112/2019 Agency to Agency Requet: 19-011
CONFIDENTIAL
SDNY_GM_00330332
EFTA_00203058
EFTA02728869
IN IRE CIRCUIT COURT Cf THE FIFTINITH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA (CRIMINAL DIVISION)
STATE or FLORIDA CASE VO. 2008CT009301AMB DIVISION: I
VS.
JEFFREY E EPSTEIN
TO: Larry Visoski
DOCKS TECUM: Flight Loge from May 1, 2009 through November 30, 2009
YOU ARE HEREBY COMMANDED to be and appear before the STATE ATTORNEY or his Assistant, in
and for Pala Beach County, Florida, at the Office of the State Attorney, 401 No. Dixie
Highway, Rest Palm Beach, Florida 33401, on Monday, December 14, 2009 at 10:00 am, for
the purpose of a deposition decus terms wherein the State of Florida is the Plaintiff
and JEFFREY I EPSTEIN is the Defendant. You are contended to bring with you the complete
and official flight logs from May 1, 2009 through December 13, 2009 concerning any and
all flights involving JIFFREY E. EPSTEIN. Failure to comply with this subpoena will
subject you to contempt of Court.
BARBARA J. BURNS
Assistant State Attorney
Fla. Bar No. 0865154
November 30, 2009
MWMW.M.i.Mta.
this s the 77 7-Ly of Atc st: 2009, and executed the same on the
171 Criday of , 2009, by delivering a Tree Copy thereof to the within named
Witness in the County of Palm Beach, State of Florida.
PAT COUNTY
0911212019 age Agency to Agency Requev 19-411
CONFIDENTIAL
3
SDNY_GM_00330333
EFTA 00203059
EFTA02728870
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Unknown
2 pages
1.
(UHFOUO) Accurint:
• aka DOB:
•
• Address: (March 2014-Nov 2021)
• Phone
• Email:
(UHFOUO) Ejustice/NCIC
• Name (both) and DOB search: Negative
(UHFOUO) Open Source:
• A Thread from PAgenthadesl: "This #EpsteinAssociate is a former model at the Ford model
Agency. She's currently living in California f (threader.app)
o Lists facebook and Linkedin: both inactive
• posted a tweet with her
F Tweet
is another Ghislaine Maxwell,
Eva Dubin ect- the older women in #Epstein circle that
procured and participated. I'm outing her after going to
her house and being yelled at. Victim blaming- not cool
Kelly. #MeToot. #EnoughlsEnough
#EpsteinDidNotKillHimself
]or of Child Development / Mom
27S connections Contact in
0 O•I A DIA Cah M Oily/A . T.A.:44.ar M. ilDiNetna
EFTA00155702
o Thread by @stoneturnr This thread will prove conclusively thataflew on
Epstein's plane [...I (twtext.coml
• Article shows listed in flight logs
EFTA00155703
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From: 'Pa"
To: '
Subject: FW: Cambridge Analytica / Trump / Royal Family / Epstein/Maxwell -
Date: Wed, 09 Sep 2020 14:03:16 +0000
Attachments: Screenshot_20200908-051559.png
From:
Sent: Wednesday, September 9, 2020 12:27 AM
To:
Subject: Cambridge Analytica / Trump / Royal Family / Epstein/Maxwell -
Dear
I am following the case against Ghislaine Maxwell with interest.
I understand that the many 'friends' of Epstein accused of abusing minors in court documents released in the
Ghislaine Maxwell proceedings will all get an opportunity to defend themselves. In other words deny all
wrongdoing.
I do not know if any accusations have been made about Nigel Oakes? He certainly runs in the same circles as
Trump and enjoys protection from within the Royal family.
He abused me when I was a child in the UK. In front of
If any young woman have named him directly then I can save them from being accused of lying. Nigel Oakes is
a pedophile and a particularly bad one from my own experience.
I have tried to ascertain whether Nigel Oakes is on the Lolita Express flight logs but have not been able to
download this data.
Rich pedophiles stick together and Nigel Oakes could easily know Jeffrey Epstein and Ghislaine Maxwell
socially and in business.
Yours sincerel
EFTA00104736
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To: Tyler Shears
Cc: Jeffre E stein • eyacation©gmall.com]
Fran:
Sent Sat 3/22/2014 6:08:01 PM
Subject: Ny post
Hi,
Ny post pushed back to bottom of 3rd page. Possible that the new flood of press alerted google
that the post was old.
So far the new stuff is still in the 'news' category and hadn't stuck to the first page.
I'll be sending a release out again on Monday at 4am.
MN'
On Mar 20, 2014, at 2:19 PM, Tyler Shears a wrote:
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
Suliect: Goo le Alert - Jeffrey Epstein
To:
Jeffrey Epstein
NEWS
Insider Selling: Jeffrey Epstein Sells 2000 Shares of
Priceline.com Stock (PCLN)
Ticker Report
Priceline.com logo Priceline. corn (NASDAQ PCLN) Director Jeffrey Epstein
unloaded 2.000 shares of the stock on the open market in a transaction ...
EFTA_R1_00380996
EFTA01930564
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 ...
Edit this alert
You have received this email because you have subscribed to Google Alerts.
Unsubscribe I View all your alerts
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Send Feedback
EFTA_R1_00380997
EFTA01930565
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IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT,
INAND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE: DAVID CROW
VS.
SCOTT ROTHSTEIN,
individually, BRADLEY J.
EDWARDS, individually,
Defendants/Counter-Plaintiff,
EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury
Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of
Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits:
All applicable criminal statutes
All applicable Florida Statutes
All applicable Rules of Evidence
Video of Jeffrey Epstein's home and route from victim to Epstein's home- Irrelevant
Order confirmation from Amazon.com for purchase of books "SM 101: A Realistic
Introduction," "Slave Craft: Roadmap for Erotic Servitude-Principles, Skills and Tools"
and "Training Miss Abernathy: A Workbook for Erotic Slaves and Their Owners"
Non-Prosecution Agreement
EFTA01113986
102 Complaint
Messages taken from message pads found at Epstein's home-
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez
Jeffrey Epstein flight logs
Jeffrey Epstein phone records
phone records
Jail Visitation Logs
Jeffrey Epstein's probation file
All probable cause affidavits related to criminal investigation of Jeffrey Epstein
All evidence, information and documents taken or possessed by FBI related to criminal
investigation of Jeffrey Epstein
Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being executed
Application for Search Warrant of Jeffrey Epstein's home
Complaint Jane Doe v. Epstein and all subsequent Amended Complaints
All records of homes, properties, bank accounts and any and all records related to Jeffrey
Epstein's assets- ok for punies only?
Jeffrey Epstein's passport (or copy)
Jeffrey Epstein's driver's license (or copy)
List of corporations owned by Jeffrey Epstein ok for punies only?
All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel
All documents evidencing relationship between Jeffrey Epstein and MC2 or any
modeling agencies
Yearbooks of Jane Doe
EFTA01113987
2002 Royal Palm Beach High School Year Book
2001 Royal Palm Beach High School Year Book
2003 Palm Beach Gardens High School Year Book
Affidavit and Application for Search Warrant on Jeffrey Epstein's home
Tape recording or transcript of recording of conversation between Jeffrey Epstein and
George Rush
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home
during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey Epstein
All documents related to Jeffrey Epstein's 6/30/08 conviction
Jeffrey Epstein's criminal plea colloquy
Public records from the Department of Corrections related to Jeffrey Epstein
Records from the Florida Department of Law Enforcement related to Jeffrey Epstein
All statements made by Jeffrey Epstein
List of properties and vehicles in Larry Visoski 's name
All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission,
Answers to Intel rngatories in this matter, and 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
All discovery related responses of Jeffrey Epstein in this matter and 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
Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him
All Complaints in which Jeffrey Epstein was a plaintiff or defendant
Jeffrey Epstein's Deposition testimony and discovery responses in this case and 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
EFTA01113988
Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM
v. Jeffrey Epstein, Case No. 502008CA028051XXXXMB AB and E.W. v. Jeffrey
Epstein, Case No. 502008CP003626)OOOCMB
Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey
Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG
Any and all newspaper articles, online articles or publications related to Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets- punies trial only
Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
Photos of all of Jeffrey Epstein's properties, cars, boats and planes punies trial only
Probable Cause Affidavits prepared against Jeffrey Epstein and
Audio tape o
Photographs, videos and books taken in the search waimnt of Jeffrey Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations to law enforcement
Victim Notification Letter from US Attorney's Office to Victim
Expert Dr. L. Dennison Reed's Report of Victim
Palm Beach Police Department Incident Report dated 4/20/06
All reports and documentation generated by Palm Beach Police Department related to
Jeffrey Epstein
All Witness Statements generated by Palm Beach Police Department relating to Jeffrey
Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs
Passenger lists for flights taken by Jeffrey Epstein
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project
Jeffrey Epstein's bank statements-punies trial only
Jeffrey Epstein's tax returns- punies trial only
EFTA01113989
MC2 emails involving communications of Jeffrey Epstein, Jeff Puller
Pappas Suat, Jean Luc Brunel and Amanda Grant
DVD of plea and colloquy taken on 6-30-08
Transcript of plea and colloquy taken on 6-30-08
Massage Table
Lotions taken from Jeffrey Epstein's home during search warrant
Computers taken from Jeffrey Epstein's home during search warrant
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search
warrant
No Contact Orders entered against Jeffrey Epstein
Criminal Score Sheet regarding Jeffrey Epstein
Documents evidencing Jeffrey Epstein's Community Control and Probation
Jeffrey Epstein's Sex Offender Registration
Jeffrey Epstein's Booking photograph
CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480
List of Jeffrey Epstein's House contacts
Documents related to Jeffrey Epstein's investments- punies trial only
Letter from Chief Michael Reiter to Barry Krischler
List of planes owned by Jeffrey Epstein
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
EFTA01113990
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
Letter from Goldberger dated 6-22-06
All subpoenas issued to State Grand Jury
Documents related to the rental of a vehicle for'
Ted's Sheds Documents
Documents related to property searches of Jeffrey Epstein's properties- punies trial only
Arrest Warrant o
Police report regardin picking up money dated 11-28-04
List of Trilateral Commission Members of 2003
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
Guy Fronstin letter dated 4-17-06
Jeffrey Epstein Account Information- punies trial only
Jeffrey Epstein Criminal Closeout Sheet-
Jeffrey Epstein Polygraph Test and Results
Victim's GED testing information and results
JEGE, Inc. Passenger Manifest
Hyperion Air Passenger Manifest
Flight infonnation fo
Passenger List Palm Beach flights 2005
Jeffrey Epstein notepad notes
Pleadings of 1 and 2 v. US case
Jeffrey Epstein 5th Amendment Speech
Reiter letter to Krisher dated 5-1-06
EFTA01113991
Jail receipts of Jeffrey Epstein
Police Report dated 11-28-04
Compulsory Medial Examination of victim, CMA
Victim's school records and transcripts
Victim Notification letter dated 7-9-08
Victim's employment records from IHOP
Police report of Juan Alessi theft at Jeffrey Epstein's home
Victim's Medical Records from Milton Girls Juvenile Facility
Victim's Medical Records from Dr. Randee Speciale
Victim's Medical Records from Wellington Regional Hospital
Victim's Medical Records from St. Mary's Medical Center
Victim's Medical Records from United Health
All surveillance conducted by law enforcement on Jeffrey Epstein's home
Emails received from Palm Beach Records related to Jeffrey Epstein
All items listed on the Palm Beach Police Property Report Lists
All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 EL
BRILLO WAY, PALM BEACH FL 33480
All copies of convictions related to Jeffrey Epstein
Jeffrey Epstein criminal records
All documents produced by Palm Beach Police Department prior to the deposition of
Detective Recarey
Photographs of all persons listed on Victims' Witness Lists
Statements, deposition transcripts, videotaped depositions and transcripts taken in
connection with this and all related cases and exhibits thereto
EFTA01113992
Any and all expert witness reports and/or records generated in preparation for this
litigation by any party to this cause
Curriculum vitaes of any and all listed experts
Curriculum vitae of Dr. Ryan Hall
Any articles or publications of Dr. Ryan Hall
Any articles or publications of Dr. Richard Hall
Any articles or publications of Dr. L. Dennison Reed
All items and documentation review by Dr. L. Dennison Reed
Transcript and video (DVD) of IME of Victims
All exhibits to Dr. L. Demlison Reed's Deposition
All exhibits to Dr. Richard Hall's Deposition
All items and documents reviewed by Dr. Richard Hall
All items and documents reviewed by Dr. Ryan Hall
All exhibits listed on the Epstein's Exhibit List
Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams
and models, surveys, photographs and similar material including blow-ups of the foresaid
items.- need to see before we agree
Any and all mortality tables
Edwards' reserves all objections to Epstein's Exhibits
Edwards reserves the right to supplement and/or amend his Exhibit List
By listing an Exhibit, Edwards is not waiving his right to object to same at trial and does
not waive their right to amend same.
All exhibits listed by Epstein subject to Edwards' objections.
All pleadings and attachments in the action under the Crime Victims Rights Act
prosecuted by Bradley Edwards on behalf of victims of Epstein's criminal molestations.
EFTA01113993
All attachments to Edwards' Motion for Summary Judgment.
All time records and hourly billing documentation produced in discovery.
All deposition testimony and discovery responses by Epstein submitted in this action.
All pleadings filed by Epstein in the Rothstein bankruptcy proceeding.
All submissions by Epstein in connection with the Rothstein deposition.
All Settlement Agreements between Epstein and victims of his sexual molestations.
EFTA01113994
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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: Robert Gary Roxburgh
YOU ARE COMMANDED to appear before a person authorized by law to take
depositions on October 13, 2009 at 4:00 p.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 September 91 , 2009.
1
EFTA00730330
Bradley J. Edwards
A- itl- jb c>3
Rothstein Rosenfeldt Adler F • r The ourt
401 East Las Olas Blvd
Suite 1650 Fen .cez, 9q
Fort Lauderdale, Florida 33301
Florida Bar No.: 542075
2
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To:
From:
Sent: Thur 3/13/2014 1:29:26 PM
Subject: Re:
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.
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Page 1 of 1
Barbara Burns
From: Bradley J. Edward
Sent: Thursday, November 12, 2009 6:52 PM
To: Barbara Bums
Subject: RE: Jeffrey Epstein
Barbara,
I am sure you have heard of the recent problems that RRA has had in the last week. As a result, I am temporarily
without an assistant, and I am not sure how to scan and send the entire deposition. I just looked through it and
don't see where we agreed to keep this deposition under seal or confidential (although we did make such an
agreement with respect to an exhibit that was attached, the flight logs). Still, I don't think any such agreement
would apply to you at the State Attorney's office. Unfortunately though, I cannot attach the deposition, but here is
the information you would need to order it - The case style was LM v. Jeffrey Epstein, deposition of Larry Visoski,
October 15, 2009 at Esquire Court Reporting at 515 N. Flagler Drive Suite P200, West Palm Beach, FL, reported
by Wendy Beath Anderson. The phone number is 866.709.8777 or 561-394-2621.
I hope this helps. If you need me to do anything else, please contact me. Good luck.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
, FL 33301
bedwands@mtlawscial
From: Barbara Bums
Sent: Thursday, November 12, 2009 4:51 PM
To: Bradley J. Edwards
Subject: Jeffrey Epstein
I have left you phone messages regarding obtaining a copy of the deposition taken of Mr. Epstein's pilot. I need a
copy asap if it has been transcribed. If not, then I need the court reporter's info so I can order a copy. This could
be advantageous to the criminal and civil cases depending upon the content. Thanks so much!!!!
09/ I 2,2019 Agency to Agency Requet 19-411
11/13/2009
CONFIt531ENTIAL
SDNY_GM_00330157
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Page 1 of 1
Barbara Bums
From: Sloane, Carmen
Sent: Tuesday, November 10, 2009 1:56 PM
To: Barbara Burns
Subject: RE: Epstein
If you give me the date of when he might have taken the flights, I can let you know what was on his schedule that
day. He have permission go to see his attorney Roy Black in Miami and he flew there in a helicopter - not sure of
the date. He have been given permission several times to go see Roy Black. I know of one time that he told the
helicopter. Give me dates and I will look on his past schedules. He was granted permission today to go to PBI
From: Barbara Burns
Sent: Tuesday, November 10, 2009 1:51 PM
To: Sloane, Carmen
Subject: RE: Epstein
Yes, there was a no contact requirement, however it never got filed in writing. I prepared one and sent it to Jack
Goldberger for his client to sign and return for filing. As to the helicopter, flying, he has not been granted
permission until today and that was just to go to the airport?
From: Sloane, Carmen [mailto
Sent: Tuesday, November 10, 2009 1:46 PM
To: Barbara Bums
Cc: Gaines, Willie
Subject: RE: Epstein
I gave him permission today to go to P81. He is ordering a customized helicopter. He needed to go into the flight
simulator to be able to customized to his fit. Have you been able to determine if there was a "No victim contact
order". If not, can you please set a status check to determine.
From: Barbara Burns
Sent: Tuesday, November 10, 2009 1:30 PM
To: Sloane, Carmen
Subject: Epstein
Could you please send me documentation where you have authorized Mr. Epstein to take helicopter flights since
he has been on house arrest/probation. Thanks so much!
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11/10/2009
CONFIDENTIAL
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Barbara Burns
From: Jack Goldberger i
Sent: Monday, November 09, 2009 11:30 AM
To: Barbara Bums
Subject: RE: Epstein
We are in agreement to no contact. My client has signed off on it, but I think I better set it for a quick hearing
because we are being sued by these girls and I want to make sure what the ground rules are for our
investigators contacting these people etc are. Are you ok for an S:45 on Nov. 18
From: Barbara Burns
Sent: Monday, November 09, 2009 11:16 AM
To: Jack Goldberger
Subject: Epstein
Has the No Contact Order been signedrmi
09/12/2019 Page Agency to Agency Requet 19-411
11/10/2009
CONFIDENTIAL
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From: Lesley Groff cza.
To: LarryVisoski Larry 41.1 >
Cc: Darren Indyke
Subject: Jeffrey's foreign trips
Date: Tae, 22 May 2018 19A5:51 +0000
Hi Larry. We are trying to secure a new Russian Visa for Jeffrey. Darren needs to know the
following:
-When did Jeffrey go to Russia? Jeffrey says he went 15 years ago. Can you give approximate
dates of this trip by looking back at flight logs? Did he go to Moscow?
-We need the past 8 foreign trips he has made...I'll bet they are Paris, Morocco...? I can look
back at my itineraries but I know sometimes he makes trips while abroad that I am not privy
to.
I know you are flying today...tomorrow is fine to have a look at this stuff for us.
Thank you! Lesley
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To: " maitcom[[email protected]]; Je vacation[[email protected]]
From:
Sent Mon 12/13/2010 2:26:15 AM
Subject Re: Dave pay
Jeffrey,
Yes you are correct on Dave's attitude, however,
Rich has not cut the check yet, when I told Dave a check would be cut for 41k, he didn't want the
money until he calculated the time also, there was a discrepancy in days worked, and also wanted
to wait till end of the year so he could accumulate more days, is what Dave told Rich.
I needed to review my flight logs that where in palm bch to verify days.
thx larry
Sent via BlackBerry by AT&T
From: Jeffrey Epstein
Date: Sun 12 Dec 2010 19:02:47 -0500
To:
Subject: Re: Dave pay
I already paid him 41k„ that was my calculation„ rich said he was very unhappy with it
On Sun, Dec 12, 2010 at 4:48 PM, wrote:
Jeffrey,
I have double check Dave's work days,.
Do you agree with paying Dave for Airline only travel days $500 ?
Currently I have him working 80 days of flight and overnights, and 21 days of airline only days,.
80 days minus the 50 days of salary, net 30days of work at $1,000 per day $30,000
Airline days 21x$50 $10,500
Total owed to date: $40,500
Do you think this is a fare deal?
Thanks,
Larry
Sent via BlackBerry by AT&T
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
EFTA_R1_00527378
EFTA02021571
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.
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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: LAWRENCE PAUL VISOSKI JR
YOU ARE COMMANDED to appear before a person authorized by law
to take depositions on October 8, 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 August 2009.
1
EFTA00730316
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
Fort Lauderdale, Florida 33301
Florida Bar No.: 542075
EFTA00730317
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From: Brad Edwards
To: jeffrey E.
Subject: RE: Re:
Date: Fri, 06 Apr 2018 16:15:20 +0000
Inline-Images: image001.png
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.
;L'EP
Brad Edwards
Board Certified Trial Attorney
From: jeffrey E. [[email protected]]
Sent: Friday, April 06, 2018 12:03 PM
To: Brad Edwards < >
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 c > 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!"
R,EF,
Brad Edwards
Board Certified Trial Attorney
please note
EFTA00841357
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
EFTA00841358
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2. Ryan Dionne
(U//FOUO) Accurint:
• Name: Ryan J Dionne, DOB:
• SSN:
• Addre
0
• Phone
Email
(U//FOUO) Ejustice (records attached)
• Name and DOB search: Positive
• FBI Number: 827028HB1
o Arrest: 7/8/1998
• Charge: Unsworn Falsification
• Charge: Resisting detention
• Arresting Agency: NH0090400 Police Department
o Arrest: 6/3/2019
• Charge: Resist Arrest/Detention a Misd
• Charge: Criminal Trespass a Misd
• Arresting Agency: NH0090800 Police Department
o Arrest: 6/22/2019
• Charge: Stalking
• Charge: Criminal Contempt
• Arresting Agency: NH0092000 Police Department
(LI) Open Source
• Jessica Dionne (taigigueredionne) / Twitter
o wife
• Jessica Giguere-Dionne - AVP, Finance Director - Benefit Strategies a Voya Financial owned
company I Linkedln
• Jessica Giguere ((a@jessica giguere) / Twitter
• Jessica Giguere-Dionne I Facebook
EFTA00155694
• Ryan Dionne I Facebook
• Flight Manifests page 16 — Epstein's Black Book (epsteinsblackbook.coml
o Listed in flight logs
o Listed in other articles regarding being on flights
• Jeffrey Epstein court doc names 70 people who 'knew of sex trafficking and underage victims.'
according to 'sex slave' — The US Sun (the-sun.com).
o Listed as former chef
• Ryan Dionne — Epstein's Black Book (epsteinsblackbook.com)
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From: Lesley Groff <1
To: Darren Indyke
Cc: Larry Visoski Larry ..a>
Subject: Fwd: Edge Vancouver Dinner update March 17, 2014
Date: Thu, 15 Feb 2018 20:04:45 +0000
This is a dinner Jeffrey attended during the TED conf. of 2014...Larry will confirm once he has a chance to
check flight logs.
Begin forwarded message:
From: John Brockman <
Subject: Edge Vancouver Dinner update
Date: March 9, 2014 at 1:36:06 PM EDT
To:
Cc: Jeffrey Epstein <
Leslie,
Here are the details and guest list below.
Date: Monday, March 17th
Time: 7:30 pm (or, at close of TED program)
Place: BLUE WATER CAFE
1095 Hamilton Street @ Helmcken St.
Vancouver BC V6B 5T4
Phone: 604.688.8078
http://www.bluewatercafe.net
Map: http. ly/IhR2RUG
Best,
JB
John Brockman
Friday March 14 - Tuesday, March 18th: Vancouver - Fairmount Waterfront Hotel
CONFIRMED TO DATE:
Jeff Bezos
Sergey Brin
David Brooks
Jeffrey Epstein
Tony Fadell &
EFTA00469644
Danielle Lambert
Salar Kamangar
Yuri Milner &
Julia Milner
Larry Page &
Lucy Page Southworth
Lori Park
Jean Pigozzi
Jacqui Safra
Ricardo Salinas &
Maria Laura Salinas
Charles Simonyi &
Lisa Simonyi
Jeff Skoll
Anne Wojcicki
John Brockman
ICatinka Matson
AWAITING RESPONSE:
Paul Allen
Dean Kamen
Marissa Mayer & Zack Bogue
Elon & Taluleh Musk
Pierre & Pam Omidyar
REGRETS:
Bill Gates
Nathan Myhrvold
Tim O'Reilly
Nick Pritzker
Evan Williams
EFTA00469645