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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: A 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
EFTA00774011
Bradley J. Edwards
Rothstein Rosenfeldt Adler For The Court
401 East Las Olas Blvd
Suite 1650
I Florida 33301
EFTA00774012
giuffre-maxwell
Unknown
5 pages
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 1 of 5
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF
PLAINTIFF’S RESPONSE IN OPPOSITION TO MOTION TO INTERVENE (DE 362)
I, Sigrid McCawley, declare that the below is true and correct to the best of my
knowledge as follows:
1. I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Support of Plaintiff’s Response in
Opposition to Motion to Intervene (DE 362).
3. Attached hereto as Exhibit 1 is a true and correct copy of January 22, 2015,
Local 10 News Article.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Flight Logs.
5. Attached hereto as Exhibit 3 is a true and correct copy of March 18, 2000, Article
from the NewsRoom.
6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from
January 16, 2015, Deposition of Virginia Giuffre.
7. Attached hereto as Exhibit 5 are a true and correct copies of July 7, 2016, Radar
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 2 of 5
Online Article.
8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of Excerpts from
September 8, 2009, Deposition of Juan Alessi.
9. Attached hereto as Exhibit 7 is a true and correct copy of January 22, 2015, Local
10 News Article.
10. Attached hereto as Sealed Composite Exhibit 8 are excerpts from the Deposition
of .
11. Attached hereto as Composite Sealed Exhibit 9 is a true and correct copy of
Excerpts the depositions of .
12. Attached hereto as Sealed Composite Exhibit 10 is a true and correct copy of
Deposition Excerpts from Detective Joseph Recarey and the Article “How Alan Dershowitz
Bullied Rape Victims to Protect a Serial Child Molester.”
13. Attached hereto as Exhibit 11 is a true and correct copy of the June 2, 2016
Notice of Appeal.
14. Attached hereto as Exhibit 12 is a true and correct copy of November 12, 2015
Order on Motion to Quash.
15. Attached hereto as Exhibit 13 is a true and correct copy of Excerpts from January
16, 2015, Deposition of Virginia Giuffre.
16. Attached hereto as Exhibit 14 is a true and correct copy of December 18, 2015,
Emergency Motion to Seal Hearing Transcript.
17. Attached hereto as Exhibit 15 is a true and correct copy of Order on Emergency
Motion to Seal.
18. Attached hereto as Exhibit 16 is a true and correct copy of the Motion for
Sanctions.
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 3 of 5
19. Attached hereto as Exhibit 17 is a true and correct copy of the Supplement to
Motion for Sanctions.
20. Attached hereto as Exhibit 18 is a true and correct copy of excerpts from the
March 17, 2016, Hearing Transcript.
21. Attached hereto as Exhibit 19 is a true and correct copy of excerpts from the
April 21, 2016, Hearing Transcript
22. Attached hereto as Exhibit 20 is a true and correct copy of January 22, 2015,
Local 10 News Article.
23. Attached hereto as Exhibit 21 is a true and correct copy of the article from CNN
International, New Day, January 6, 2015.
24. Attached hereto as Exhibit 22 is a true and correct copy of the article from
Australian Broadcasting System (ABC), January 6, 2015.
25. Attached hereto as Exhibit 23 is a true and correct copy of the article from
Newsmax, April 8, 2015.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley______________
Sigrid S. McCawley, Esq.
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 4 of 5
Dated: August 29, 2016.
Respectfully Submitted,
BOIES, 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
(954) 356-0011
4
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 5 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of August, 2016, I electronically filed the
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served to all parties of record via transmission of the Electronic
Court Filing System generated by CM/ECF.
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: [email protected]
[email protected]
/s/ Meredith L. Schultz
Meredith L. Schultz
5
dnc-emails
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Michael C. Short Tweet
5/13/16 3:25 PM
Read Here
Fox News: Flight logs show Bill Clinton flew on sex offender's jet much more than previously known fxn.ws/1TaZ8ac
Flight logs show Bill Clinton flew on sex offender's jet much more than previously knownflight-logs-show-bill-clinton-flew-on-sex-offenders-jet-much-more-than-previously-known.html>
By Malia Zimmerman
Published May 13, 2016
[Epstein, (inset left), and Clinton flew together at least 26 times on the disgraced financier's "Lolita Express." (John Coates, airport-data.com)]
Epstein, (inset left), and Clinton flew together at least 26 times on the disgraced financier's "Lolita Express." (John Coates, airport-data.com)
Former President Bill Clinton was a much more frequent flyer on a registered sex offender's infamous jet than previously reported, with flight logs showing the former president taking at least 26 trips aboard the "Lolita Express" -- even apparently ditching his Secret Service detail for at least five of the flights, according to records obtained by FoxNews.com.
Clinton's presence aboard Jeffrey Epstein's Boeing 727 on 11 occasions has been reported, but flight logs show the number is more than double that, and trips between 2001 and 2003 included extended junkets around the world with Epstein and fellow passengers identified on manifests by their initials or first names, including "Tatiana." The tricked-out jet earned its Nabakov-inspired nickname because it was reportedly outfitted with a bed where passengers had group sex with young girls.
"Bill Clinton ... associated with a man like Jeffrey Epstein, who everyone in New York, certainly within his inner circles, knows is a pedophile," said Conchita Sarnoff, of the Washington, D.C. based non-profit Alliance to Rescue Victims of Trafficking, and author of an upcoming book on the Epstein case called "TrafficKing." "Why would a former president associate with a man like that?"
Epstein, who counts among his pals royal figures, heads of state, celebrities and fellow billionaires, spent 13 months in prison and home detention for solicitation and procurement of minors for prostitution. He allegedly had a team of traffickers who procured girls as young as 12 to service his friends on "Orgy Island," an estate on Epstein's 72-acre island, called Little St. James, in the U.S. Virgin Islands.
Virginia Roberts, 32, who claims she was pimped out by Epstein at age 15, has previously claimed she saw Clinton at Epstein's getaway in 2002, but logs do not show Clinton aboard any flights to St. Thomas, the nearest airsport capable of accommodating Epstein's plane. They do show Clinton flying aboard Epstein's plane to such destinations as Hong Kong, Japan, Singapore, China, Brunei, London, New York, the Azores, Belgium, Norway, Russia and Africa.
Among those regularly traveling with Clinton were Epstein's associates, New York socialite Ghislaine Maxwell and Epstein's assistant, Sarah Kellen, both of whom were investigated by the FBI and Palm Beach Police for recruiting girls for Epstein and his friends.
Official flight logs filed with the Federal Aviation Administration show Clinton traveled on some of the trips with as many as 10 U.S. Secret Service agents. However, on a five-leg Asia trip between May 22 and May 25, 2002, not a single Secret Service agent is listed. The U.S. Secret Service has declined to answer multiple Freedom of Information Act requests filed by FoxNews.com seeking information on these trips. Clinton would have been required to file a form to dismiss the agent detail, a former Secret Service agent told FoxNews.com.
In response to a separate FOIA request from FoxNews.com, the U.S. Secret Service said it has no records showing agents were ever on the island with Clinton.
A Clinton spokesperson did not return emails requesting comment about the former president's relationship and travels with Epstein. The Clinton Library said it had no relevant information and does not keep track of Clinton's travel records.
Martin Weinberg, Epstein's current attorney, did not respond to multiple inquiries. Epstein said in a court filing said that he and his associates "have been the subject of the most outlandish and offensive attacks, allegations, and plain inventions."
However, hundreds of pages of court records, including reports from police and FBI agents, reviewed by FoxNews.com, show Epstein was under law enforcement scrutiny for more than a year.
Police in Palm Beach, Fla., launched a year-long investigation in 2005 into Epstein after parents of a 14-year-old girl said their daughter was sexually abused by him. Police interviewed dozens of witnesses, confiscated his trash, performed surveillance and searched his Palm Beach mansion, ultimately identifying 20 girls between the ages of 14 and 17 who they said were sexually abused by Epstein.
In 2006, at the request of Palm Beach Police, the FBI launched a federal probe into allegations that Epstein and his personal assistants had "used facilities of interstate commerce to induce girls between the ages of 14 and 17 to engage in illegal sexual activities."
According to court documents, police investigators found a "clear indication that Epstein's staff was frequently working to schedule multiple young girls between the ages of 12 and 16 years old literally every day, often two or three times per day."
One victim, in sworn deposition testimony, said Epstein began sexually assaulting her when she was 13 years old and molested her on more than 50 occasions over the next three years. The girls testified they were lured to Epstein's home after being promised hundreds of dollars to be his model or masseuse, but when they arrived, he ordered them to take off their clothes and massage his naked body while he masturbated and used sex toys on them.
The U.S. Attorney for the Southern District of Florida prepared charging documents that accused Epstein of child sex abuse, witness tampering and money laundering, but Epstein took a plea deal before an indictment could be handed up.
On Sept. 24, 2007, in a deal shrouded in secrecy that left alleged victims shocked at its leniency, Epstein agreed to a 30-month sentence, including 18 months of jail time and 12 months of house arrest and the agreement to pay dozens of young girls under a federal statute providing for compensation to victims of child sexual abuse.
In exchange, the U.S. Attorney's Office promised not to pursue any federal charges against Epstein or his co-conspirators.
Florida attorney Brad Edwards, who represented some of Epstein's alleged victims, is suing the federal government over the secret non-prosecution agreement in hopes of having it overturned. Edwards claimed in court records that the government and Epstein concealed the deal from the victims "to prevent them from voicing any objection, and to avoid the firestorm of controversy that would have arisen if it had become known that the Government was immunizing a politically-connected billionaire and all of his co-conspirators from prosecution of hundreds of federal sex crimes against minor girls."
The U.S. Attorney for the Southern District of Florida did not respond to a request for comment about the deal.
Other politicians, celebrities and businessmen, including presidential candidate Donald Trump, have been accused of fraternizing with Epstein. Trump lawyer Alan Garten told FoxNews.com in a statement Trump and Epstein are not pals.
"There was no relationship between Jeffrey Epstein and Donald Trump," he said. "They were not friends and they did not socialize together."
Lauren Hendricks
DataSet-10
Unknown
18 pages
Epstein Accuser Sues Alan Dershowitz Over Alleged Sex Ring
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Photo Illustration by The Daily Beast/Getty/Handout
A new accuser has come forward against Jeffrey Epstein, claiming the billionaire pedophile and his
alleged madam, British socialite Ghislaine Maxwell, sexually assaulted her and her underage sister on
different occasions in the 1990s.
The allegations surfaced Tuesday as part of a defamation suit filed against
Harvard law professor Alan Dershowitz a friend and attorney of Epstein's who helped secure
controversial plea deal for Epstein after he was arrested in 2006 for molesting dozens of minor girls at
his Palm Beach mansion.
the alleged victim, also claims she witnessed Dershowitz visit Epstein's Manhattan
mansion and head upstairs, where she says underage girls were present.
has long claimed Epstein kept her as a "sex slave" and loaned her to his famous friends including
Prince Andrew. (Both men have vehemently denied this claim.) She filed the lawsuit against Dershowitz
in New York federal court, claiming the high-profile defense lawyer "was also a participant in sex
trafficking, including as one of the men to whom Epstein lent out M I for sex."
MONEY MAN
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REVEALED: We Found Jeffrey Epstein's Secret Charity
Kate Briquelet
The complaint accuses Dershowitz of employing "a desperate barrage of false and increasingly
defamatory attacks" on after a Miami Herald investigation revealed how Epstein and his lawyers
obtained the jnfamous non-prosecution agreement that essentially resulted in Epstein getting a slap on
the wrist for abusing the underage girls. Epstein served 13 months of his 18-month sentence for crimes
that could have sent him to prison for life.
Dershowitz has recently accused and her lawyers of framing him in order to get millions of
dollars from Epstein's only known client, Limited Brands chairman Leslie Wexner. He also accused
another Epstein accuser. , of fabricating recent claims that she was coerced into sex with
Dershowitz. (In response, Dershowitz called accusations "delusional" and claimed he'd never
met her.)
Indeed, Dershowitz challenged his accusers to sue him for defamation.
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In response to the lawsuit, Dershowitz told The Daily Beast on Tuesday: "I welcome it. This lawsuit gives
me the opportunity I've been looking for to prove has committed perjury and will
continue to commit perjury in federal court."
"I am asking the FBI to come to this trial because perjury will be committed in front of a federal judge
and in a federal courtroom," Dershowitz added. "And I will prove it is she who is committing perjury."
"I will prove it from her own mouth as I have documents from her that acknowledges that I was not one
of the people that she had sex with," Dershowitz said.
The Daily Beast has left messages for attorneys for Maxwell and Epstein, and put in a call for comment
from Wexner on Tuesday.
In the affidavit, says she was an artist and grad student in New York City in 1995, when
she met Epstein and his alleged madam, Maxwell, at an art show. The following summer, she alleges, the
pair sexually assaulted in Ohio—and molested her 15-year-old sister at Epstein's ranch in New
Mexico.
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Acosta Defends Secret Epstein Deal: We Were Too Aggressive'
NXIVM 'Slave': Women Forced Me Into Sex With Founder
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Maria Butina: I'm a Peacemaker, Not a Spy
The duo are accused of sexually assaulting while she stayed at Wexner's Ohio mansion. At the
time, Epstein had allegedly enlisted for a special art project at Wexner's property, where she
stayed along with her younger brothers.
"She alleges the pair sexually assaulted her in Ohio—and molested her 15-
year-old sister at Epstein's ranch in New Mexico."
"Epstein said that if I sold him one of my paintings for half price he would help me with my career,"
stated of their first meeting. "I sold him the painting that night for half price which was
approximately $6,000."
Months later, claims in the court filing, Epstein called her and claimed he was looking for an art
consultant. But instead, was hired to become a lookout for the front door of Epstein's East 71st
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Street mansion. Her job involved "manning the front door at his New York mansion and keeping records
of people who came to the home," she said.
"During the time I was supervising the door at Epstein's mansion, I witnessed a number of school age
girls coming to the home, some of the young girls would be wearing their school uniforms,"
affidavit added. Those girls would enter Epstein's Upper East Side property, then be escorted upstairs,
claimed.
"When I asked Maxwell why these young girls were coming over to the house so often she said that the
girls were interviewing for modeling positions," stated. "At the time, based on my observations at
the home, it did not seem credible to me that these young girls were interviewing for modeling
positions."
"During the time I was supervising the door at Epstein's mansion, I witnessed
a number of school age girls coming to the home, some of the young girls
would be wearing their school uniforms..."
Dershowitz visited Epstein's New York residence "a number of times" while worked for Epstein,
she said. "Dershowitz was very comfortable at the home and would come in and walk upstairs,"
added. She claims Dershowitz went upstairs at the same time minor girls were present there.
Dershowitz denied claims, telling The Daily Beast: `'stopped working for Epstein
before I ever met Epstein. It's a totally perjured affidavit. It's all totally made up. For her lawyers to
submit these obviously perjured affidavits raises serious questions about their role in this case."
Meanwhile, claims her younger sister, who was 15 years old, was abused by Epstein and Maxwell,
too.
"Maxwell and Epstein took an interest in my younger sister. Epstein took us to a movie in New York and
during the movie he held my younger sister's hand and was rubbing her in a sexual manner without my
knowledge," said in her affidavit.
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Epstein "then contacted my mother and said he wants to help put my younger sister through a special
school program in Thailand," added.
That summer, Epstein and Maxwell allegedly flew younger sister to Epstein's ranch in New
Mexico, where they molested her on a massage table, the affidavit alleges.
The duo is accused of touching the girl inappropriately after directing her to remove her clothes and get
on a massage table. "It was not until later in the summer when I called my sister in Thailand where she
was studying that I learned what had happened to her at Epstein's New Mexico ranch," stated in
the court filing.
"I called the FBI and made the report but to my knowledge, the FBI did not
take any action against Epstein or Maxwell."
While worked on her art project at Wexner's mansion, she claims, Maxwell and Epstein sexually
assaulted her. "They asked me to come into a bedroom with them and then proceeded to sexually assault
me against my will," said. "I fled the room and called the sheriffs office but did not get any
response."
Wexner's security, said, refused to let her leave the property. "I was held against my will for
approximately twelve hours until I was ultimately allowed to leave with my father," said. Her
father had driven to Ohio from Kentucky to get her.
claims that when she returned to New York and went to police at the Sixth Precinct for help,
officers allegedly told her to contact the FBI to make a report about the supposed Ohio assault.
"I called the FBI and made the report but to my knowledge, the FBI did not take any action against
Epstein or Maxwell," stated. "To my knowledge I was the first person to report Maxwell and
Epstein to the FBI."
After the alleged assault, Maxwell and Epstein called multiple times to threaten her,
claims. The pair also called her art clients and people in New York's art world in a bid to destroy her
career, the affidavit states.
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"Maxwell and Epstein worked in concert to make sure that my career and my life was ruined,"
stated. "I was terrified of Maxwell and Epstein and I moved a number of time to try to hide from them."
"I have struggled throughout my life as a direct result of Epstein and Maxwell's actions against me and
my hope is that they will be held accountable for their crimes," concluded in the affidavit. "While
I am still afraid, I am coming forward because I think it is so important to do so."
"'Roberts was forced to engage in sexual acts with Dershowitz in, among
other locations, Epstein's mansion' in New York City, the lawsuit claims."
complaint provides further details on the scope of Epstein's alleged sex-trafficking operation,
citing flight logs of the financier's private jet. A graphic of a map inside the complaint shows flights to
Tangier, Granada, London and Paris.
"During the time period that Roberts was being trafficked by Epstein she was forced to have sex with
Alan Dershowitz," the lawsuit adds. "Roberts was forced to engage in sexual acts with Dershowitz in,
among other locations, Epstein's mansion" in New York City.
accuses Dershowitz of lying about flying on Epstein's private plane, dubbed the "Lolita Express"
by the media, which he claims he took only with his wife. The lawyer traveled on Epstein's jet with young
women, including a Victoria's Secret model, the complaint alleges.
Dershowitz is also accused by of lying about his involvement with another of Epstein's alleged
victims, who now lives in Spain and says she was introduced to Epstein in 2006 when
she was 22 and living in New York.
Soon after meeting Epstein, he allegedly flew her to his private isle in the Virgin Islands, where he
directed her to have sex with him and "various other girls and guests," according to an affidavit by
, filed as part of lawsuit.
claims Epstein at one point arranged for Dershowitz to represent her, and during that time,
also "lent her out to Dershowitz for sex," the complaint alleges.
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"At his town house I was also lent out by him to his friends and associates to have sex." said of
Epstein in the court filing.
"She was a woman that was trying to sell a story to the New York Post that
she had sex tapes of Hillary Clinton, Donald Trump, Bill Clinton and Richard
Branson."
— Alan Dershowitz
"Among the people he lent me to was his friend, Alan Dershowitz," stated in the filing, dated
April 8 2019.
"On one occasion I was in a bedroom at Jeffrey's New York townhouse with Jeffrey and
97
added, referring to a woman identified as one of Epstein's alleged "sex slaves."
"After a short time, Alan Dershowitz entered the room, after which Jeffrey left the room and and I
had sex with Dershowitz," concluded. "I recall specific, key details of his person and the sex
acts and can describe them in the event it becomes necessary to do so."
Dershowitz, as he has in the past, denied ever knowing
"I've never met her. I was never her lawyer," Dershowitz told The Daily Beast.
"She was a woman that was trying to sell a story to the New York Post that she had sex tapes of Hillary
Clinton, Donald Trump, Bill Clinton and Richard Branson," Dershowitz added. "She claimed to have had
sex with practically everyone under the sun, but not me."
Kate Briquelet
Lachlan Cartwright
Got a tip? Send it to The Daily Beast here
MAN'S BEST FRIEND?
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New Hope for Lonely Senior Citizens:
Robopets
That's a good boy—er, bot.
lb I
Tanya Basu
05.09.19 4:22 PM ET
Robopets, which behave like real-life dogs and cats, can offer similar health benefits to humans,
researchers found in a review published Thursday in the International Journal of Older People Nursing.
Just like Fido, they'll listen, play, and snuggle up to you. And just like Fido, they might be able to help
ease the grating pain of loneliness, which study after study has called an epidemic, particularly for elderly
people.
That might sound dystopian—like the beginning of the end for living, breathing furry friends—but
Rebecca Abbott, a researcher at the University of Exeter Medical School and lead author of the new
report, said that the results offer promising hope for those suffering from loneliness.
"In care homes, we know that loneliness for some can be an issue," she said. "Having a robopet to talk to,
or talk about with someone, can be one of the ways which may help reduce loneliness."
A DOG BY ANY OTHER NAME
The Robo-dogs Are Coming. Will They Love Us?
Jack Crosbie
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Abbott and her colleagues collected data from 19 surveys conducted over the past 15 years, looking at the
interactions between about 9OO senior citizens in nursing homes in Britain and their caretakers and
family members. Most of the studies used parQ an interactive robotic seal that "remembers" previous
actions and will respond to behavioral cues. Other robopets studied included Justocat (cat), Aibo (dog),
and Coddler (bear).
She and her colleagues were surprised to find that not only were robopets welcomed, they worked. The
study reported that residents found they reduced agitation and allowed them to express their emotions.
Many patients had previously described themselves as "restless or sad" or "bored" but found robopets a
welcome distraction, injecting their lives with "humor and play" and allowing them not only a way to talk
and express themselves, but also to engage in conversation with others—a crucial way for elderly citizens
to connect with others and maintain health.
Intriguingly, many residents found themselves stroking, hugging, and kissing the robopets-fully aware
that the pets weren't real. Some even reported developing deep emotional attachments, with one woman
noting, "I know it is an inanimate object but I can't help but love her."
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NICE AND FRIENDLY
Will Care-Bots Cure the Loneliness of Nursing Homes?
Joelle Renstrom
This isn't the first time humans have developed feelings, even become attached, to robotic creatures.
Remember the Tamagotchi trend of the '90s, when every kid checked digital monitors frequently to make
sure they were feeding and interacting with a digital pet avatar before it "died."
And robopets have long held promise as a companion for their elderly, with a Wired story quoting Alan
Beck, director of the Center for the Human-Animal Bond at Purdue University, saying the puppy Aibo
"elicits similar responses [to living pets], even while people are quite aware of the differences... It has a
nice animal shape. People appreciate the eyes and the tail."
In fact, humans have long held deep emotional bonds with their robots, even if they're not meant to be
companions One Georgia Tech study of 30 "committed" users found that two-thirds of them had gone so
far as to name their devices and half had assigned a gender; one person went so far as to introduce their
Roomba to their parents. And a live demonstration of people interacting with a Pleo dinosaur robot
showed humans were hesitant—downright disturbed—to "torture" their robots.
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GOOD DOGGY
Meet Our Animal Robot Overlords
James Joiner
Abbott's study found that that emotional attachment was just as strong with the elderly and their
robopets, to the point where some could only communicate their pain to the robopet. One quote from
one of the reports from a nursing home stood out to Abbott and her team, of a resident who was suffering
from dementia-induced anxiety and used a robopet to "verbalize how she was feeling... she could see that
she was thinking about her thoughts and she wanted to pass it on to somebody."
That's not to say robotpets were a magical cure-all to elderly loneliness. Some residents found the robotic
antics predictable and boring.
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Will Care-Bots Cure the Loneliness of Nursing Homes?
I
The Anti-Vax Movement Ls Now Infecting the Pet World
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Couple Claims Clinic Implanted Embryo of Different Race
Abbott pointed out that many of these studies looked at robopets for a limited amount of time."We still
don't know about the long-term use of robopets," Abbott said. "Does the novelty wear off?"
What's more, Abbott's study looked at a slim population of people who had access to the cutting-edge
technology. Robopets aren't projected to be an expensive investment compared to their real-life versions
(in fact, they might be cheaper in the long run because robots don't need to eat or relieve themselves),
but they're available only in limited quantities, which means that only a certain subset of the population
has access to them.
"I know it is an inanimate object but I can't help but love her."
— One robopet owner
That said, robopets offer some surprising benefits. There's no pet dander to deal with, so if you've ever
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wistfully gazed at a pet owner giggling with their pup and sighed because your immune system can't
handle the onslaught of pet hair, robopets could offer an alternative (remember the Tamagotchis?).
The lack of pet fur all over the place also means that they're cleaner. In a shared living community like a
nursing home, that means less cleanup and frustration, and more bonding time.
Further studies are necessary to understand if having previously had a pet might help prime and prepare
people to be more receptive to robopets.
"We found a wide variation in the response to them: men and women, residents living with dementia and
those without dementia all appeared to engage with robopets," Abbott said. "It may be that people who
had pets before going into the care home might be more receptive, but we don't know that answer. It also
might depend on the type of robopet."
Abbott is ultimately confident that we are entering the age of the robopet lovingly tackling their owner as
they step in their house, saying that while the concept might seem uncomfortable to some, the
"technology means that there will be likely more choice of robopets in the future and they may become
more affordable too."
And that goes far beyond grandma and grandpa, Abbott predicted. "There is no reason why the responses
from the older adults in care homes wouldn't be the same for children and adults in other locations."
Tanya Basu
Got a tip? Send it to The Daily Beast hem.
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25 pages
Case 9:08-cv-80736-KAM Document 212 Entered on FLSD Docket 07/19/2013 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Matthewman
JANE DOES #1 AND #2,
Petitioners,
I
UNITED STATES OF AMERICA,
Respondent,
UNITED STATES' NOTICE OF FILING PRIVILEGE LOG
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
States of America, by and through the undersigned Assistant United States Attorney, hereby gives
notice of its filing of its Privilege Log, which is attached hereto.
The documents referenced in the Privilege Log are being delivered today to the Chambers
of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's
Omnibus Order.
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By: s/A. Marie Villa/aim
A. MARIE VILLAFANA
Assistant United States Attorney
Florida Bar No. 0018255
500 South Australian Ave, Suite 400
West Palm Beach, FL 33401
Telephone: 561-820-8711
Facsimile: 561-820-8777
[email protected]
EFTA00211385
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 19, 2013, I electronically filed the foregoing document
with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties
are able to receive notice via the CM/ECF system.
s/A. Marie Villafaiia
A. MARIE VILLAFAIZIA
Assistant United States Attorney
SERVICE LIST
Jane Does 1 and 2 v. United States,
Case No. 08-80736-CIV-MARRA/MATTHEWMAN
United States District Court, Southern District of Florida
Brad Edwards, Esq.,
Farmer Jaffe Weissing Edwards Fistos Lehrman
425 N Andrews Ave Ste 2
Fort Lauderdale, FL 33301-3268
[email protected]
954-524-2820
Fax: 954-524-2822
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
332 S. 1400 E.
Salt Lake City, Utah 84112
(801) 585-5202
Fax: (801) 585-6833
E-mail: [email protected]
Attorneys for Jane Doe # 1 and Jane Doe # 2
2
EFTA00211386
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PRIVILEGE LOG
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "CORR RE GJ 6(e)
P-000001 SUBPOENAS" containing correspondence Work Product
thru related to various grand jury subpoenas and
P-000039 attorney (Villafafia) handwritten notes
Box #1 Operation Leap Year Grand Jury Log 6(e)
P-000040 containing subpoenas OLY-01 through OLY-81, Work Product
thru correspondence and research related to Contains documents subject
P-000549 enforcement of same, documents produced in to investigative privilege
response to some subpoenas; and attorney Also contains documents
(Villafafia) handwritten notes subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies of a sealed search warrant Contains information subject
thru application, warrant, and supporting documents to investigative privilege
P-000621 Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "PNY Technologies Compact 6(e)
P-000622 Flash SW" containing copies of a sealed search Contains information subject
thru warrant application, warrant, and supporting to investigative privilege
P-000693 documents Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "JE Corporations" containing Work Product
P-000694 attorney research on Epstein-owned corporations Contains information subject
thru and prior litigation to investigative privilege
P-000781
Box #1 File folder entitled "Capital One" 6(e)
P-000782 containing subpoena and correspondence
thru
P-000803
Box #1 File folder entitled "DTG Operations/Dollar 6(e)
P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and
thru documents information subject to
P-000854 investigative privilege
Also contains documents and
information subject to privacy
rights of victims who are not
parties to this litigation
Page 1 of 23
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Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "JP Morgan Chase" 6(e)
P-000855 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000937 investigative privilege
Box #1 File folder entitled "Washington Mutual" 6(e)
P-000938 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000947 investigative privilege
Box #1 File folder entitled "Computer Search &" Work Product
P-000948 containing legal research on computer search and Attorney-Client
thru handwritten notes on indictment preparation Contains information subject
P-000982 to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Attorney Notes from Work product
P-000983 Document Review" containing typed and 6(e)
thru handwritten attorney (Villafafia) notes, target Contains information subject
P-001007 letters, correspondence re grand jury subpoena to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Notes from Fed Ex Records" Work Product
P-001008 containing handwritten and typed attorney 6(e)
thru (Villafafia) notes and screen shots of FedEx Contains information subject
P-001056 subpoena response electronic file to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Colonial Bank Records" 6(e)
P-001057 containing records received in response to grand Contains information subject
thru jury subpoena to investigative privilege
P-001959
Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e)
P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject
Thru numbered OLY-51 through OLY-81 with related to investigative privilege.
P-002089 correspondence Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Page 2 of 23
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Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Epstein Corporate Records: 6(e)
P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and
Thru subpoenas, records received in response to documents subject to
P-002169 subpoenas, and related correspondence investigative privilege
Box #1 File folder entitled "Colonial Bank" containing 6(e)
P-002170 subpoenas, correspondence related to subpoenas, Contains information and
Thru records received in response to subpoenas documents subject to
P-002246 investigative privilege
Box #1 File folder entitled "JEGE & Hyperion from 6(e)
P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and
Thru documents received in response to subpoenas documents subject to
P-002265 investigative privilege
Box #1 Indictment preparation binder containing: Work product
P-002266 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002386 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, of individuals listed as contains information and
"Additional victims" documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Indictment preparation binder containing: Work product
P-002387 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart, witness/victim names and contact Contains information and
P-002769 list, attorney (Villafafia) handwritten notes, 302s, documents subject to
portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #15, 16, 17, 18,
19, Past Employees, Misc. Witnesses
Box #1 Indictment preparation binder containing: Work product
P-002770 witness/victim list with identifying information, 6(e)
Thru sexual activity summary, telephone call summary Contains information and
P-003211 chart, attorney (Villafafia) handwritten notes, documents subject to
302s, portions of state investigative file, attorney investigative privilege. Also
(Villafafia) typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
8
Page 3 of 23
EFTA00211389
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23
Bates Range Description Privilege(s) Asserted
Box #1 Indictment preparation binder containing meta- Work product
P-003212 analysis charts of telephone/flight/grand jury 6(e)
Thru information for a number of victim/witnesses, Contains information and
P-003545 -• and documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 FBI Reports of March 2008 interviews of Work product
P-003546 additional witness/victim located in New York 6(e)
Thru Contains information and
P-003552 documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Printout of filenames from Federal Express Work product
P-003553 subpoena response with Attorney notations 6(e)
Thru
P-003555B
Box #1 Document entitled "Identified Numbers" with Work product
P-003556 accompanying handwritten attorney list compiled 6(e)
Thru from grand jury materials and attorney analysis of Contains information subject
P-003562 records to investigative privilege
Box #1 Folder entitled "Flight Manifests" containing 6(e)
P-003563 manifests received pursuant to grand jury Contains information and
Thru subpoena documents subject to
P-003629 investigative privilege
Box #1 File folder entitled "Recent Attorney Notes" Work product
P-003630 containing handwritten attorney (Villafafia) notes 6(e)
Thru regarding document review and case strategy Investigative privilege
P-003633 Deliberative process
Box #1 File folder bearing victim name containing FBI Work product
P-003634 interview report from May 2008, telephone Attorney-client privilege
Thru activity report with attorney (Villafanafia) 6(e)
P-003646 handwritten notes, related grand jury material Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 4 of 23
EFTA00211390
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Summary of Sexual Activity" Work product
P-003647 containing chart bearing handwritten title "Sexual 6(e)
Thru Activity — Summary" with meta-analysis of Investigative privilege
P-003651 information, sorted by name of each Deliberative process
victim/witness, including name and identifying Also contains information and
information of each victim/witness documents subject to privacy
rights of victims who are not
arties to this liti ation
Box #1 File folder entitled "Victim Civil Suits" Not privileged.
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research re JE Websites" Work product
P-003664 containing attorney research
Thru
P-003678
Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product
P-003679 containing attorney (Villafafia) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. Anna Salter" containing Work product
P-003681 attorney (Villafafia) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 File folder entitled "I[] G[] Interview" containing Work product
P-003688 attorney handwritten notes of interview, and Investigative privilege
Thru attorney handwritten notes regarding potential Also contains information
P-003693 charges subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Research re Travel for Work product
P-003694 Prostitution" containing attorney (Villafafia) 6(e)
Thru handwritten notes regarding grand jury Investigative privilege
P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and
House" with handwritten notes, Message Pad documents subject to privacy
meta-analysis chart, summary of evidence related rights of victims who are not
to one victim/witness, and relevant grand jury parties to this litigation
information
Box #1 Empty file folder bearing name of victim/witness Investigative privilege
P-003712 Also contains information
subject to privacy rights of
victim who is not a party to
this liti ation
Page 5 of 23
EFTA00211391
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "T[] M[]" containing grand 6(e)
P-003713 jury subpoenas, motion and order to compel Documents under seal
Thru testimony, and correspondence regarding same pursuant to court order
P-003746
Box #1 File folder entitled' M'' containing 6(e)
P-003747 subpoena and correspondence regarding same
Thru
P-003751
Box #1 File folder entitled "PBPD Investigative File" 6(e)
P-003752 obtained via subpoena Investigative privilege
Thru Also contains information and
P-004295 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work product
P-004296 containing meta-analysis chart showing telephone 6(e)
Thru calls, travel, and grand jury materials relevant to Investigative privilege
P-004350 possible charges Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Daniel Gonzalez Documents Work product
P-004351 53909-004" containing attorney research related
Thru to bias issue
P-004381
Box #1 File Folder entitled "FEDEX" containing 6(e)
P-004382 documents obtained via subpoena Investigative privilege
Thru
P-004478
Box #1 File Folder entitled "State of Delaware Records" 6(e)
P-004479 containing documents obtained in preparation for Investigative privilege
Thru indictment Work product
P-004551
Box #1 File folder entitled "Jet Blue Records" containing 6(e)
P-004552 documents obtained via subpoena Work product
Thru Investigative privilege
P-004555 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege
P-004556 RECORDS" containing FDLE records on targets Work product
Thru and witnesses obtained at attorney request
P-004560
Page 6 of 23
EFTA00211392
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Bates Range Description Privilege(s) Asserted
Box #1 Filed folder entitled "JANUSZ BANASIAK" Work product
P-004561 containing attorney (Villafafia) handwritten notes Investigative privilege
Thru of interview
P-004565
Box #1 File folder entitled "JANUSZ BANASIAK 6(e)
P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product
Thru documents obtained via subpoena Investigative privilege
P-004716 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "IGOR ZINOVIEV" Work product
P-004717 containing attorney research regarding witness Investigative privilege
Thru
P-004722
Box #1 File folder entitled "BEAR STEARNS Work Product
P-004723 RESEARCH" containing attorney research Investigative privilege
Thru regarding potential witness and subpoena
P-004725 recipient
Box #1 File folder entitled "LAWSUITS INVOLVING Work Product
P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege
Thru regarding Epstein's past personal and business
P-004819 litigative practices
Box #1 Filed folder entitled "SEC RECORDS" Work Product
P-004820 containing attorney research regarding Epstein Investigative privilege
Thru financial relationships
P-004959
Box #1 File folder entitled "Message Pads" containing Work Product
P-004960 selected items from evidence obtained via 6(e)
Thru subpoena Investigative privilege
P-005059 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work Product
P-005060 containing correspondence with counsel for 6(e)
Thru victim/witness, attorney witness outline with Investigative privilege
P-005081 attorney handwritten notes, attorney handwritten Also contains information and
notes regarding witness reports and case documents subject to privacy
preparation rights of victims who are not
parties to this litigation
Box #1 File folder entitled "New York Trip" containing Work product
P-005082 attorney notes re witness interview Investigative privilege
Thru
P-005083
Page 7 of 23
EFTA00211393
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23
Bates Range Description Privilege(s) Asserted
P-005084 thru P-005107 are non responsive
documents and have been removed
Box #1 File folder entitled "ANNA SALTER" containing Work product
P-005108 attorney research on select expert, use of experts Investigative privilege
Thru at trials in child exploitation cases, and additional
P-005193 research materials on offenders and victims
Box #1 File folder entitled "Extra Copies" containing Work product
P-005194 meta-analysis chart and 302's of victim/witnesses 6(e)
Thru used in preparing indictment package Investigative privilege
P-005300 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "JUAN ALESSI 6(e)
P-005301 STATEMENT' containing transcript obtained via Investigative privilege
Thru subpoena
P-005331
Box #1 File folder entitled "KEN LANNING" containing Work product
P-005332 attorney research on select expert, including Investigative privilege
Thru attorney handwritten notes
P-005341
Box #1 File folder entitled "Info re Planes" containing 6(e)
P-005342 correspondence regarding subpoenas and Investigative privilege
Thru documents received in response to subpoenas
P-005387
Box #1 File folder entitled "Police Reports & PC Work product
P-005388 Affidavit" containing portions of police reports 6(e)
Thru with attorney notes, related phone records, a list Investigative privilege
P-005442 entitled "Victims" with identifying information Also contains information and
and attorney handwritten notes, photographs and documents subject to privacy
DAVID information, and additional attorney rights of victims who are not
research regarding Epstein sexual activity parties to this litigation
Box #1 File folder entitled "[Victim name] Transcript of 6(e)
P-005443 Interview & GJ Transcript" Investigative privilege
Thru Also contains information and
P-005496 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Bear Stearns Subpoena 6(e)
P-005497 Resp." containing material received in response Investigative privilege
Thru to subpoena
P-005556
Page 8 of 23
EFTA00211394
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Bates Range Description Privilege(s) Asserted
Box #1 U.S. Attorney's Office Criminal Case File Jacket Work product
P-005557 containing file opening documents, expert Deliberative process
Thru witness payment documents
P-005576
Box #1 U.S. Attorney's Office Asset Forfeiture Case File Work product
P-005578 Jacket containing file opening and file closing Deliberative process
Thru documents
P-005583
Box #1 File folder entitled "6001 Immunity Request" 6(e)
P-005584 containing internal memoranda seeking witness Work product and
Thru immunity and correspondence with counsel for deliberative process (as to
P-005606 witness regarding same internal memoranda)
Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "MASTER PHONE Work product
P-005607 RECORDS" containing meta-analysis of all 6(e)
Thru phone, travel, and grand jury data for all Investigative privilege
P-005914 victim/witnesses for indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-005915 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-005977 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-005978 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-006050 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-006051 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-006065 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 9 of 23
EFTA00211395
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23
Bates Range Description Privilege(s) Asserted
Box #2 File folder entitled "JANE DOE #4" containing Work product
P-006066 meta-analysis of all phone, travel, and grand jury 6(e)
Thru data related to that victim/witness for indictment Investigative privilege
P-006220 preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled 'JANE DOE #12" containing Work product
P-006221 meta-analysis of all phone, travel, and grand jury 6(e)
Thru data related to that victim/witness for indictment Investigative privilege
P-006222 preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "CORRECTED PHONE Work product
P-006223 RECORDS 5/31/07" containing meta-analysis of 6(e)
Thru all phone, travel, and grand jury data related to all Investigative privilege
P-006522 victims/witnesses for indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "[Victim Name] Phone Work product
P-006523 Records" containing telephone records received 6(e)
Thru in response to subpoena Investigative privilege
P-006802 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "Lists of Identified Phone Work product
P-006803 Numbers" containing charts of information culled 6(e)
Thru from grand jury materials, interviews, and other Investigative privilege
P-006860 investigation, with attorney handwritten notes, Also contains information and
and information to issue follow-up grand jury documents subject to privacy
subpoena rights of victims who are not
arties to this liti ation
Box #2 File folder entitled' CELL Work product
P-006861 PHONE RECORDS" containing documents 6(e)
Thru received via subpoena with attorney handwritten Investigative privilege
P-007785 notes and highlighting Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 10 of 23
EFTA00211396
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23
Bates Range Description Privilege(s) Asserted
Box #2 Folder entitled "OLY GRAND JURY LOG: Work product
P-007786 OLY-01 THROUGH OLY-50" containing 6(e)
Thru subpoenas, correspondence regarding same, 6(e) Investigative privilege
P-008120 letters, attorney handwritten notes regarding Also contains information and
records received in response to subpoenas documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 Handwritten flight logs received in response to 6(e)
P-008121 subpoena Investigative privilege
Thru
P-008139
Box #2 Grand jury presentation folder containing Work product
P-008140 attorney handwritten notes, typed outline with 6(e)
Thru additional handwritten notes, complete indictment Investigative privilege
P-008298 package dated 2/19/2008, victim list with Also contains information and
identifying information, photographs, and documents subject to privacy
summary of activity rights of victims who are not
parties to this litigation
Box #2 File folder entitled "FINAL AGREEMENTS"
P-008299 containing subfolder entitled "Agrmts Filed in
Thru State Court" (P-008300-P-008327 [not being
P-008363 withheld as privileged — have been produced to
opposing counsel]); signed Non-Prosecution
Agreement, Addendum, and operative portion of
12/19/2007 Sanchez-Acosta letter (P-008328-P-
008343 [not being withheld as privileged — have
been produced to opposing counsel]); subfolder
entitled "12/19/07 Acosta-Sanchez Ltr"
containing unredacted copies of that letter (P-
008344-P-008363 [pursuant to Court's Order, not
being withheld as privileged — will be produced
to opposing counsel upon lift of stay by 11th
Circuit])
Box #2 File folder entitled "Lacerda Immunity Request" 6(e)
P-008364 containing internal memoranda, Justice Work Product
Thru Department documentation, and subpoena Deliberative Process
P-008382 regarding immunity request Investigative privilege
Box #2 File folder containing March 18, 2008 grand jury Work product
P-008383 presentation materials, including "Operation Leap 6(e)
Thru Year Revised Indictment Summary Chart (by Investigative privilege
P-008516 victim)," grand jury materials, draft indictments, Deliberative process
victim reference list, grand jury subpoena log Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 11 of 23
EFTA00211397
Case 9:08-cv-80736-KAM Document 212
DataSet-10
Unknown
6 pages
August 4, 2021 Larry Visoski VTC Prep
AUSA
Det.
Attorneys Glen McGorty, Danielle Giffuni, Daniel Zelenko
Prepared for trial testimony.
• Employer from 1991 through 2019 was Jeffrey Epstein, though was paid by NES LLC,
reported to JE
o 1991 until 2000, job titles were captain and aircraft maintenance
o 2000 until 2019, job title was chief pilot
• First hired in approximately July 1991 in Columbus, OH by JE
o LV was living in Columbus, OH and working at the flight department next door
to the Limited's flight department. One day, the Limited's chief pilot came to
Dave Rodgers and LV and said that a friend of Mr. Wexner's was looking for
pilots. DR's employer was selling its airplane, so LV and DR agreed to be
introduced to JE
o LV and DR were hired together and started working as pilots for JE together from
1991 through 2000. In 2000, they swapped roles because JE did not like the way
DR flew the plane (specifically did not like the way DR landed the plane). After
2000, LV hired Bill Hammond to be another pilot for JE.
• Job responsibilities 1991 through 2000 included tracking the maintenance on the aircraft
and flying JE's planes as a captain
• Job responsibilities 2000 through 2019 as chief pilot included record keeping and flight
scheduling.
• Pilots for JE kept the following records:
o Flight log — kept track of total time on the aircraft, engine total time, and when
certain checks were due on the airplane
o Passenger manifest — kept track of the date of the flight, to and from which
airport, exact time took off and landed, and passengers. If pilots did not know a
passenger's name, would either put male or female.
• Whoever was captain would complete the manifest for each leg of a flight,
and would complete the manifest either during the flight or about 30 or 45
minutes after the flight.
o The Pilots kept the paperwork in a binder in the plane, and then about once a
month would fax the paperwork to JE's personal assistant.
o LV's recollection is that he turned over a number of records to one of JE's
attorneys in or about 2006. LV recalls definitely turning over the records for
1999 through 2006, and will check to confirm that he also turned over all records
pre-1999
• During LV's employment with JE, JE owned the following:
o First a Hawker Sidley HS125 (1991-1994)
o Then in approximately 1994, bought a Gulfstream 2B
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00010053
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o Approx. 2001 bought Boeing 727 and kept both the G2 and the Boeing at that
point
o Approx. 2013 sold G2B and bought a G4
o Approx. 2016 sold the G4 and bought the G550
o Also owned helicopters
• G2B interior:
o Baseball glove leather, club seating for four, dining room table with two forward
facing seats, behind that a divan, kitchen in the back.
o Door separated passengers from pilots, was closed during flights, so pilots
couldn't observe what passengers were doing during flights
• Boeing interior:
o Walk in and a very open floorplan, there was a couch and two chairs facing
forward with a TV, behind that two couches facing each other with cocktail table
and another passenger chair, in the middle was the kitchen, past the kitchen was
the round room with two semi-circle couches, then JE's office with a desk and
two chairs and a red couch, then there was a bedroom with a queen sized bed and
two passenger chairs, then the bathroom in the back of that, also a bathroom at the
front of the plane.
o Every room or compartment had a door, so had a cockpit door and then each room
had shut doors. Cockpit door was always closed in flight. So pilots could not
observe what passengers were doing. A handful of times, the pilots may have
gotten coffee during a flight, but infrequent.
• Between 1994 and 2004, flew JE's planes approximately every four or five days, but had
not set schedule and no set routine.
o During that same period, the pilots received notice of upcoming flights from
either one of JE's assistants, JE himself, or Ghislaine Maxwell.
o At first, received notice via a beeper and would call the office to speak with an
assistant, or sometimes JE. With the advent of cellphones, would get a call, and
GM would sometimes call LV on the phone.
o Typically received about one day's notice of an upcoming flight
o Between 1994 and 2004, LV would call JE's assistant if there was a problem with
one of the planes. Was very rare to call JE directly.
o Between 1994 and 2004, JE took the Concord to Europe or took airlines when his
plane was under maintenance, but otherwise only flew privately
o LV did not have much interaction with passengers on the flights other than JE and
GM because would either be up in the cockpit, or possible standing in the
doorway when passengers arrive. So would have minimal interaction, possibly
some small talk, but not much more.
o LV learned the names of passengers when either JE, GM, or one of the assistants
told the pilots the names, and many passengers became frequent fliers, so came to
recognize them.
2
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o LV did not learn the name of every single passenger who flew on JE's planes.
That was because there were passengers who were not regular repeats, and the
pilots did not have the opportunity to gather those passengers' names.
• GM
o LV first met GM in or about 1991 and recalls that he began working for JE before
GM did
o GM had shoulder-length black hair, a British accent, was attractive, and was
about 29 years old when LV first met her
o LV recalls that GM was on almost every flight from 1991 through the 2000s
o In or about 2006 or 2007, LV noticed that GM broke away from JE and spent
significantly less time flying with JE
o Earlier on, GM she was an orchestrator who took care of JE's properties. Seemed
to be an employee, then later on seemed to be more of a girlfriend.
o Approx. 1991 through 1994, GM had a desk at Jeffrey's office at his office in
NYC and had an assistant who helped her.
o In approximately the mid-1990s, GM appeared to be interacting romantically with
JE.
o After that, GM still took care of the properties, involved in the decorating, the
buying of everything. GM would talk about the work she was doing on the
houses.
o In the mid or late 1990s, GM told LV that she had a share in a beach jet that she
had because she was tired of riding the airlines, which she had taken sometimes.
• LV visited several of GM's residences in NY during his employment with JE. LV went
to GM's residences to pick up luggage and to help her with home entertainment systems.
o When LV first met GM, she was living in a small apartment in or about 1991.
o Then in the mid-1990s, GM moved to an apartment on 84th Street, which was
bigger.
o Then in or about 2000, GM had a 5-story brownstone on 65ih Street. 65th Street
Brownstone was a mini-version of JE's residence on 7181 street, entrance foyer,
upstairs was living room, then in back on same floor was kitchen, third floor was
guest bedrooms, fourth floor was master bedroom, fifth floor was home theater,
and housekeeper lived on that floor too.
• JE's office was located at 457 Madison Avenue until 2006. JE also had an office in
Columbus, OH when LV first met JE.
o LV went to JE's NY office about once a week to turn in expenses. It was on the
fourth floor, come out of elevator to a receptionist, then accounting with four
desks, if walk down corridor then personal assistant, to the left was Jeffrey's
office, to the right was Ghislaine Maxwell's desk and office area and an office in
the middle for the attorneys.
• LV visited all of JE's residences during his employment with JE. Among other reasons,
LV visited the residences to set up home theater equipment and TVs at JE's residence.
o At first, JE lived on 69th Street in NYC, then about two or three years after LV
started working for JE, JE moved to 71g Street.
3
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EFTA_00010055
EFTA00159727
• LV been to 71° Street residence multiple times. Would go at least once a
month to pick up luggage, also set up home theater there.
• Giant front doors as walk in, left hand side had a round office where
personal assistant would be based, across from that room is the security
room with TV monitors monitoring the outside of the house, inside spiral
staircase leading up to house, butlers kitchen, dining room, next floor is
living room and gym, third floor master bedroom, sixth floor home
theater, above that was the house manager's area.
• If in Gulfstream, flew to Teterboro when JE was going to NY residence,
but Boeing was too big for Teterboro, so in Boeing would go to Newark,
JFK, or White Plains.
o Palm Beach
• LV been to PB many times. Bermuda style house, kitchen in the back,
entrance to the front on the side of the street, semi-circle staircase up to
bedrooms, pool in the back with dock on the intercoastal, pool house was
JE's office with exercise room and stereo system in it, later on built staff
quarters on the property.
• Flew to PBI when JE was staying at the PB residence
o Zorro Ranch in Santa Fe, NM
• LV went to the ranch approximately 5 or 6 times per year. Visited the
main residence on the ranch at least once per year. LV set up home
entertainment system in the main residence on the ranch.
• Ranch property, entrance had Ranch Central where all ranch hands and
managers stayed; also had a barn with stalls for at least 15 horses,
greenhouse, fire department there, three houses for the people who lived
on the ranch to support it. About 4 miles to JE's main house, which was a
40,000 square foot house that was square and open in the middle.
• JE got the ranch around the mid-1990s, at which point LV would stay in
Ranch Central. Around 2000, LV got 40 acres of land and built a home on
the ranch.
• Approximately mid-I990s, the ranch was under construction. At first, JE
put a triple wide mobile home on one of the cliffs and stayed there for a bit
trying to get a feel for the area, and then at some point moved the mobile
home to where the main house site was. JE lived in the mobile
home/lodge for a couple years while the main house was under
construction, which completed approximately around 2000.
• When JE was staying at the ranch, between 1991 and 2000, landed in
Santa Fe airport, in 2000 when had Boeing, would land in Albuquerque
o Little St. James Island in St. Thomas USVI
• LV been to the island many times because flew the helicopter there.
Visited approximately twice per month during employment with JE.
• Island had a helipad, tennis court on main hill, house was a separated
house, meaning living room was its own building, master building own
4
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00010056
EFTA00159728
house, kitchen own house, guest bedrooms were their own bungalow
houses, had two pools one by main compound and another by the flagpole
with a main office.
• When JE was staying on the island, would fly into the main airport on St.
Thomas in USVI.
o Apartment in Paris
• LV visited about five times
• Apartment was on the second floor of the building, there was an entrance
foyer, JE's office straight ahead, kitchen to the left, then long corridor
with all bedrooms. LV was in the master once to put a TV in the master
bedroom. Otherwise, LV only went there to pick up luggage.
• When JE staying at Paris apartment, typically flew into Le Bourget, but
may have landed at Charles de Gaulle if there were weather issues.
• LV recalls flying Epstein to the airport in Traverse City, Michigan maybe twice a year in
the earlier years of his employment with JE. LV recalls that it was warm when they flew
to Traverse City.
o LV understood that JE travelled to Traverse City to visit Interlochen music camp
because JE was into the arts. Both JE and LV played piano.
o LV definitely remembers JE and Itzhak Perlman flying to Traverse City, but
cannot recall either way whether GM or went on any of those trips.
o LV went into the main lobby of Interlochen once to pick up luggage. Cannot
recall how long the drive was from airport to camp, may have been between 30
minutes and an hour.
• LV recalls flying a passenger
o LV recalls meeting in or about the mid-1990s
o Jeffrey introduced to LV when LV was in the pilot's seat. JE brought up
to show her the cockpit and said this is
. LV recalled that
o LV remembers being on the plane at least once, doesn't recall where were
going or who else was on the plane.
• LV recalls flying passenger whose name was named
o LV recalls meeting in or about the early 2000s.
o as a regular on the airplane.
o LV recalls meeting
• LV recalls flying one passenger with the first name
o LV met in or about the early 2000s.
o LV recalls that JE traveled with many females, and there were times when three
or four females were on the flights, and LV did not get to know them.
o • wasn't a long-term regular on the plan, but LV recalls taking at least 10
flights with JE, mostly on the Boeing.
• LV recalls GM had assistants named and 'MI LV
recalls started working as JE's assistant in or around the early 2000s.
5
3527-012
Page 5 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFIA_00010057
EFTA00159729
Giglio questions:
6
3527-012
Page 6 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000 10058
EFTA00159730
DataSet-10
Unknown
25 pages
Case 9:08-cv-80736-KAM Document Entered on FLSD Docket 07/19/2013 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Matthewman
JANE DOES #1 AND #2,
Petitioners,
I
UNITED STATES OF AMERICA,
Respondent,
UNITED STATES' NOTICE OF FILING PRIVILEGE LOG
Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United
States of America, by and through the undersigned Assistant United States Attorney, hereby gives
notice of its filing of its Privilege Log, which is attached hereto.
The documents referenced in the Privilege Log are being delivered today to the Chambers
of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's
Omnibus Order.
Respectfully submitted,
WIFREDO A. FERRER
UNITED STATES ATTORNEY
By:
Assistant United States Attorney
Florida Bar No.
500 South Australian Ave, Suite 400
West Palm Beach. FL 33401
EFTA00223825
Case 9:08-cv-80736-KAM Document Entered on FLSD Docket 07/19/2013 Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 19, 2013, I electronically filed the foregoing document
with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties
are able to receive notice via the CM/ECF system.
Assistant United States Attorney
SERVICE LIST
Jane Does 1 and 2 United States,
Case No. 08-80736-CIV-MARRA/MATTHEWMAN
United States District Court, Southern District of Florida
Brad Edwards, Esq.,
Farmer Jaffe Weissing Edwards Fistos Lehrman
425 N Andrews Ave Ste 2
Fort Lauderdale FL 33301-3268
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
332 S. 1400 E.
Salt Lake Cit Utah 84112
Fax:
E-mail:
Attorneys for Jane Doe # 1 and Jane Doe # 2
2
EFTA00223826
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23
PRIVILEGE LOG
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "CORR RE GJ 6(e)
P-000001 SUBPOENAS" containing correspondence Work Product
thru related to various rand jury subpoenas and
P-000039 attorney handwritten notes
Box #1 Operation Leap Year Grand Jury Log 6(e)
P-000040 containing subpoenas OLY-01 through OLY-81, Work Product
thru correspondence and research related to Contains documents subject
P-000549 enforcement of same, documents produced in to investigative privilege
response to some subpoenas; and attorney Also contains documents
( handwritten notes subject to privacy rights of
victims who are not parties to
this liti ation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies of a sealed search warrant Contains information subject
thru application, warrant, and supporting documents to investigative privilege
P-000621 Also contains information
subject to privacy rights of
victims who are not parties to
this liti ation
Box #1 File folder entitled "PNY Technologies Compact 6(e)
P-000622 Flash SW" containing copies of a sealed search Contains information subject
thru warrant application, warrant, and supporting to investigative privilege
P-000693 documents Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "JE Corporations" containing Work Product
P-000694 attorney research on Epstein-owned corporations Contains information subject
thru and prior litigation to investigative privilege
P-000781
Box #1 File folder entitled "Capital One" 6(e)
P-000782 containing subpoena and correspondence
thru
P-000803
Box #1 File folder entitled "DTG Operations/Dollar 6(e)
P-000804 Rent-a-Car" containing subpoena and responsive Contains documents and
thru documents information subject to
P-000854 investigative privilege
Also contains documents and
information subject to privacy
rights of victims who are not
parties to this litigation
Page 1 of 23
EFTA00223827
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 2 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "JP Morgan Chase" 6(e)
P-000855 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000937 investigative privilege
Box #1 File folder entitled "Washington Mutual" 6(e)
P-000938 containing subpoena, correspondence, and Contains documents and
thru responsive documents information subject to
P-000947 investigative privilege
Box #1 File folder entitled "Computer Search &" Work Product
P-000948 containing legal research on computer search and Attorney-Client
thru handwritten notes on indictment preparation Contains information subject
P-000982 to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Attorney Notes from Work product
P-000983 Document Review" containing typed and 6(e)
thru handwritten attorney ( ) notes, target Contains information subject
P-001007 letters, correspondence re grand jury subpoena to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Notes from Fed Ex Records" Work Product
P-001008 containing handwritten and typed attorney 6(e)
thru ) notes and screen shots of FedEx Contains information subject
P-001056 subpoena response electronic file to investigative privilege.
Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Colonial Bank Records" 6(e)
P-001057 containing records received in response to grand Contains information subject
thru jury subpoena to investigative privilege
P-001959
Box #1 File folder entitled "OLY Grand Jury Log Vol 2: 6(e)
P-001960 OLY-51 THROUGH" containing subpoenas Contains information subject
Thru numbered OLY-51 through OLY-81 with related to investigative privilege.
P-002089 correspondence Also contains information
subject to privacy rights of
victims who are not parties to
this litigation
Page 2 of 23
EFTA00223828
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 3 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Epstein Corporate Records: 6(e)
P-002090 OLY-51, OLY-52, OLY-53, OLY-54" containing Contains information and
Thru subpoenas, records received in response to documents subject to
P-002169 subpoenas, and related correspondence investigative privilege
Box #1 File folder entitled "Colonial Bank" containing 6(e)
P-002170 subpoenas, correspondence related to subpoenas, Contains information and
Thru records received in response to subpoenas documents subject to
P-002246 investigative privilege
Box #1 File folder entitled "JEGE & Hyperion from 6(e)
P-002247 Goldberger OLY-46 & OLY-47" containing Contains information and
Thru documents received in response to subpoenas documents subject to
P-002265 investigative privilege
Box #1 Indictment preparation binder containing: Work product
P-002266 Grand jury subpoena log, evidence/activity 6(e)
Thru summary chart witness/victim names and contact Contains information and
P-002386 list, attorney ( handwritten notes, 302s, documents subject to
'lions of state investigative file, attorney investigative privilege. Also
) typed notes, of individuals listed as contains information and
"Additional victims" documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Indictment preparation binder containing: Work product
P-002387 Grand jury subpoena log, evidence/activity 6(e)
Thru summary charta_witness/victim names and contact Contains information and
P-002769 list, attorney ( handwritten notes, 302s, documents subject to
as of state investigative file, attorney investigative privilege. Also
( typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #15, 16, 17, 18,
19, Past Employees, Misc. Witnesses
Box #1 Indictment preparation binder containing: Work product
P-002770 witness/victim list with identifying information, 6(e)
Thru sexual activity summ telephone call summary Contains information and
P-003211 chart, attorney handwritten notes, documents subject to
3CSsfions of state investigative file, attorney investigative privilege. Also
( typed notes, relevant pieces of grand contains information and
jury materials, telephone records/flight records documents subject to privacy
analysis charts, victim/witness photographs, rights of victims who are not
DAVID records, NCICs, and related materials for parties to this litigation
persons identified as Jane Does #1, 2, 3, 4, 5, 6, 7,
8
Page 3 of 23
EFTA00223829
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 4 of 23
Bates Range Description Privilege(s) Asserted
Box #1 Indictment preparation binder containing meta- Work product
P-003212 analysis charts of telephone/flight/grand jury 6(e)
Thru information for a number of victim/witnesses, Contains information and
P-003545 and documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 FBI Reports of March 2008 interviews of Work product
P-003546 additional witness/victim located in New York 6(e)
Thru Contains information and
P-003552 documents subject to
investigative privilege. Also
contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 Printout of filenames from Federal Express Work product
P-003553 subpoena response with Attorney notations 6(e)
Thru
P-003555B
Box #1 Document entitled "Identified Numbers" with Work product
P-003556 accompanying handwritten attorney list compiled 6(e)
Thru from grand jury materials and attorney analysis of Contains information subject
P-003562 records to investigative privilege
Box #1 Folder entitled "Flight Manifests" containing 6(e)
P-003563 manifests received pursuant to grand jury Contains information and
Thru subpoena documents subject to
P-003629 investigative privilege
Box #1 File folder entitled "Recent Attibites" Work product
P-003630 containing handwritten attorney ) notes 6(e)
Thru regarding document review and case strategy Investigative privilege
P-003633 Deliberative process
Box #1 File folder bearing victim name containing FBI Work product
P-003634 interview report from May 2008. telephone Attorney-client privilege
Thru activity report with attorney ( ) 6(e)
P-003646 handwritten notes, related grand jury material Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 4 of 23
EFTA00223830
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 5 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "Summary of Sexual Activity" Work product
P-003647 containing chart bearing handwritten title "Sexual 6(e)
Thru Activity — Summary" with meta-analysis of Investigative privilege
P-003651 information, sorted by name of each Deliberative process
victim/witness, including name and identifying Also contains information and
information of each victim/witness documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Victim Civil Suits" Not privileged.
P-003652 Produced to counsel for
Thru Petitioners
P-003663
Box #1 File folder entitled "Research re JE Websites" Work product
P-003664 containing attorney research
Thru
P-003678
Box #1 File folder entitled "Serene Cano (N.Y. AUSA)" Work product
P-003679 containing attorney (IIIIII) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. Anna Salter" containing Work product
P-003681 attorney ( ) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 File folder entitled "In G[] Interview" containing Work product
P-003688 attorney handwritten notes of interview, and Investigative privilege
Thru attorney handwritten notes regarding potential Also contains information
P-003693 charges subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Research re Travel for Work product
P-003694 Prostitution" containing attorney ( ) 6(e)
Thru handwritten notes regarding grand jury Investigative privilege
P-003711 presentation, chart entitled "Brought to Epstein's Also contains information and
House" with handwritten notes, Message Pad documents subject to privacy
meta-analysis chart, summary of evidence related rights of victims who are not
to one victim/witness, and relevant grand jury parties to this litigation
information
Box #1 Empty file folder bearing name of victim/witness Investigative privilege
P-003712 Also contains information
subject to privacy rights of
victim who is not a party to
this litigation
Page 5 of 23
EFTA00223831
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 6 of 23
Bates Range Description Privilege(s) Asserted
Box #1 File folder entitled "T[] M[]" containing grand 6(e)
P-003713 jury subpoenas, motion and order to compel Documents under seal
Thru testimony, and correspondence regarding same pursuant to court order
P-003746
Box #1 File folder entitled ' ' containing 6(e)
P-003747 subpoena and correspondence regarding same
Thru
P-003751
Box #1 File folder entitled "PBPD Investigative File" 6(e)
P-003752 obtained via subpoena Investigative privilege
Thru Also contains information and
P-004295 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work product
P-004296 containing meta-analysis chart showing telephone 6(e)
Thru calls, travel, and grand jury materials relevant to Investigative privilege
P-004350 possible charges Also contains information and
documents subject to privacy
rights of victims who are not
arties to this liti ation
Box #1 File folder entitled ' Documents Work product
P-004351 53909-004" containing attorney research related
Thru to bias issue
P-004381
Box #1 File Folder entitled "FEDEX" containing 6(e)
P-004382 documents obtained via subpoena Investigative privilege
Thru
P-004478
Box #1 File Folder entitled "State of Delaware Records" 6(e)
P-004479 containing documents obtained in preparation for Investigative privilege
Thru indictment Work product
P-004551
Box #1 File folder entitled "Jet Blue Records" containing 6(e)
P-004552 documents obtained via subpoena Work product
Thru Investigative privilege
P-004555 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "FL EMPLOYMENT Investigative privilege
P-004556 RECORDS" containing FDLE records on targets Work product
Thru and witnesses obtained at attorney request
P-004560
Page 6 of 23
EFTA00223832
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23
Bates Range Description Privilege(s) Asserted
Box #1 Filed folder entitled "JANUSZ BANASIAK" Work product
P-004561 containing attorney ( ) handwritten notes Investigative privilege
Thru of interview
P-004565
Box #1 File folder entitled "JANUSZ BANASIAK 6(e)
P-004566 RECORDS 23-0001 THROUGH 23-" containing Work product
Thru documents obtained via subpoena Investigative privilege
P-004716 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "IGOR ZINOVIEV" Work product
P-004717 containing attorney research regarding witness Investigative privilege
Thru
P-004722
Box #1 File folder entitled "BEAR STEARNS Work Product
P-004723 RESEARCH" containing attorney research Investigative privilege
Thru regarding potential witness and subpoena
P-004725 recipient
Box #1 File folder entitled "LAWSUITS INVOLVING Work Product
P-004726 EPSTEIN CORP'S" containing attorney research Investigative privilege
Thru regarding Epstein's past personal and business
P-004819 litigative practices
Box #1 Filed folder entitled "SEC RECORDS" Work Product
P-004820 containing attorney research regarding Epstein Investigative privilege
Thru financial relationships
P-004959
Box #1 File folder entitled "Message Pads" containing Work Product
P-004960 selected items from evidence obtained via 6(e)
Thru subpoena Investigative privilege
P-005059 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder bearing name of victim/witness Work Product
P-005060 containing correspondence with counsel for 6(e)
Thru victim/witness, attorney witness outline with Investigative privilege
P-005081 attorney handwritten notes, attorney handwritten Also contains information and
notes regarding witness reports and case documents subject to privacy
preparation rights of victims who are not
parties to this litigation
Box #1 File folder entitled "New York Trip" containing Work product
P-005082 attorney notes re witness interview Investigative privilege
Thru
P-005083
Page 7 of 23
EFTA00223833
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 8 of 23
Bates Range Description Privilege(s) Asserted
P-005084 thru P-005107 are non responsive
documents and have been removed
Box #1 File folder entitled "ANNA SALTER" containing Work product
P-005108 attorney research on select expert, use of experts Investigative privilege
Thru at trials in child exploitation cases, and additional
P-005193 research materials on offenders and victims
Box #1 File folder entitled "Extra Copies" containing Work product
P-005194 meta-analysis chart and 302's of victim/witnesses 6(e)
Thru used in preparing indictment package Investigative privilege
P-005300 Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "JUAN ALESSI 6(e)
P-005301 STATEMENT' containing transcript obtained via Investigative privilege
Thru subpoena
P-005331
Box #1 File folder entitled "KEN LANNING" containing Work product
P-005332 attorney research on select expert, including Investigative privilege
Thru attorney handwritten notes
P-005341
Box #1 File folder entitled "Info re Planes" containing 6(e)
P-005342 correspondence regarding subpoenas and Investigative privilege
Thru documents received in response to subpoenas
P-005387
Box #1 File folder entitled "Police Reports & PC Work product
P-005388 Affidavit" containing portions of police reports 6(e)
Thru with attorney notes, related phone records, a list Investigative privilege
P-005442 entitled "Victims" with identifying information Also contains information and
and attorney handwritten notes, photographs and documents subject to privacy
DAVID information, and additional attorney rights of victims who are not
research regarding Epstein sexual activity parties to this litigation
Box #1 File folder entitled "[Victim name] Transcript of 6(e)
P-005443 Interview & GJ Transcript" Investigative privilege
Thru Also contains information and
P-005496 documents subject to privacy
rights of victims who are not
parties to this litigation
Box #1 File folder entitled "Bear Stearns Subpoena 6(e)
P-005497 Resp." containing material received in response Investigative privilege
Thru to subpoena
P-005556
Page 8 of 23
EFTA00223834
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 9 of 23
Bates Range Description Privilege(s) Asserted
Box #1 U.S. Attorney's Office Criminal Case File Jacket Work product
P-005557 containing file opening documents, expert Deliberative process
Thru witness payment documents
P-005576
Box #1 U.S. Attorney's Office Asset Forfeiture Case File Work product
P-005578 Jacket containing file opening and file closing Deliberative process
Thru documents
P-005583
Box #1 File folder entitled "6001 Immunity Request" 6(e)
P-005584 containing internal memoranda seeking witness Work product and
Thru immunity and correspondence with counsel for deliberative process (as to
P-005606 witness regarding same internal memoranda)
Investigative privilege
Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "MASTER PHONE Work product
P-005607 RECORDS" containing meta-analysis of all 6(e)
Thru phone, travel, and grand jury data for all Investigative privilege
P-005914 victim/witnesses for indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-005915 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-005977 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-005978 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-006050 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder bearing name of victim/witness Work product
P-006051 containing meta-analysis of all phone, travel, and 6(e)
Thru grand jury data related to that victim/witness for Investigative privilege
P-006065 indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 9 of 23
EFTA00223835
Case 9:08-cv-80736-KAM Document IMI-1 Entered on FLSD Docket 07/19/2013 Page 10 of
23
Bates Range Description Privilege(s) Asserted
Box #2 File folder entitled "JANE DOE #4" containing Work product
P-006066 meta-analysis of all phone, travel, and grand jury 6(e)
Thru data related to that victim/witness for indictment Investigative privilege
P-006220 preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled 'JANE DOE #12" containing Work product
P-006221 meta-analysis of all phone, travel, and grand jury 6(e)
Thru data related to that victim/witness for indictment Investigative privilege
P-006222 preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "CORRECTED PHONE Work product
P-006223 RECORDS 5/31/07" containing meta-analysis of 6(e)
Thru all phone, travel, and grand jury data related to all Investigative privilege
P-006522 victims/witnesses for indictment preparation Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 File folder entitled "[Victim Name] Phone Work product
P-006523 Records" containing telephone records received 6(e)
Thru in response to subpoena Investigative privilege
P-006802 Also contains information and
documents subject to privacy
rights of victims who are not
arties to this liti ation
Box #2 File folder entitled "Lists of Identified Phone Work product
P-006803 Numbers" containing charts of information culled 6(e)
Thru from grand jury materials, interviews, and other Investigative privilege
P-006860 investigation, with attorney handwritten notes, Also contains information and
and information to issue follow-up grand jury documents subject to privacy
subpoena rights of victims who are not
parties to this litigation
Box #2 File folder entitled "EPSTEIN, CELL Work product
P-006861 PHONE RECORDS" containing documents 6(e)
Thru received via subpoena with attorney handwritten Investigative privilege
P-007785 notes and highlighting Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 10 of 23
EFTA00223836
Case 9:08-cv-80736-KAM Document IM -1 Entered on FLSD Docket 07/19/2013 Page 11 of
23
Bates Range Description Privilege(s) Asserted
Box #2 Folder entitled "OLY GRAND JURY LOG: Work product
P-007786 OLY-01 THROUGH OLY-50" containing 6(e)
Thru subpoenas, correspondence regarding same, 6(e) Investigative privilege
P-008120 letters, attorney handwritten notes regarding Also contains information and
records received in response to subpoenas documents subject to privacy
rights of victims who are not
parties to this litigation
Box #2 Handwritten flight logs received in response to 6(e)
P-008121 subpoena Investigative privilege
Thru
P-008139
Box #2 Grand jury presentation folder containing Work product
P-008140 attorney handwritten notes, typed outline with 6(e)
Thru additional handwritten notes, complete indictment Investigative privilege
P-008298 package dated 2/19/2008, victim list with Also contains information and
identifying information, photographs, and documents subject to privacy
summary of activity rights of victims who are not
parties to this litigation
Box #2 File folder entitled "FINAL AGREEMENTS"
P-008299 containing subfolder entitled "Agrmts Filed in
Thru State Court" (P-008300-P-008327 [not being
P-008363 withheld as privileged — have been produced to
opposing counsel]); signed Non-Prosecution
Agreement, Addendum, and operative portion of
12/19/2007 Sanchez-Acosta letter (P-008328-P-
008343 [not being withheld as privileged — have
been produced to opposing counsel]); subfolder
entitled "12/19/07 Acosta-Sanchez Ltr"
containing unredacted copies of that letter (P-
008344-P-008363 [pursuant to Court's Order, not
being withheld as privileged — will be produced
to opposing counsel upon lift of stay by 11ih
Circuit
Box #2 File folder entitled ' Immunity Request" 6(e)
P-008364 containing internal memoranda, Justice Work Product
Thru Department documentation, and subpoena Deliberative Process
P-008382 regarding immunity request Investigative privilege
Box #2 File folder containing March 18, 2008 grand jury Work product
P-008383 presentation materials, including "Operation Leap 6(e)
Thru Year Revised Indictment Summary Chart (by Investigative privilege
P-008516 victim)," grand jury materials, draft indictments, Deliberative process
victim reference list, grand jury subpoena log Also contains information and
documents subject to privacy
rights of victims who are not
parties to this litigation
Page 11 of 23
EFTA00223837
Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 12 of
23
Bates Range Description Privilege(s) Asserted
Box #2 6/25/2007 Letter from Gerald Lefcourt .
P-008517
Thru [pursuant to Court's Order, not being withheld as
P-008535 privileged — will be produced to opposing counsel
upon lift of stay by 11'" Circuit]
Box #2 Handwritten attorney notes to prepare for Work product
P-008536
DataSet-10
Unknown
2 pages
From:
Sent: Monday, June 20, 2011 2:11 PM
To:
Subject: Re: JE on the island?
I reminded her! Ha!
On Jun 20, 2011, at 10:02 AM, rote:
> oh my...ok...so you are all out there. did Memember to brirs
> her ID=with her for her flight ! ;) On Jun 20, 2011, at 9:58 AM, wrote:
» She came along with-
» On Jun 20, 2011, at 9:55 AM, rote:
>» oh gosh...I hope he is not a crazy man to y'all. It makes it so hard...roar...so are you both on the island with him
or did she stay to do sch=ol stuff?
>»
>» On Jun 20, 2011, at 9:49 AM, wrote:
>»
»» Yes, it is crazy. I havent really seen him yet today, so not sure.
»» Yes=erday he was fine to me, but not so much to I'm a little
»» on edge to be=honest since there is so much still to do here and
»» I'm sure he won't be hap=y it's not all done yet
>>»
»» On Jun 20, 2011, at 9:43 AM,
»» wrote:=»»
>»» ok, thanks. how is the mood?!
>>>»
>>>» le emailed me on frida askin me "why is everything so sloppy" becaus= I reminded him that Darren was going
to work from home and take 1= a concert! I had no idea that ?! No one told m=...l
was at Hershey Park! just crazy really.
>>>»
>>>»
>»» On Jun 20, 2011, at 8:45 AMarote:
>>>»
>>»» We had wheelsup yesterday at 6:15pm to LSJ from Teterboro
>>>>»
>>»» On Jun 20, 2011, at 7:36 AM, wrot=:
>>>>»
>>>»» Did plans go as planned? Did JE leave for the island sat nite
>>>»» afterMparty ? Did Larry fly? I will need flight log...
>>>»» Get me up to date.=Thx..
>>>>>»
>>>»» Sent from my iPhone
>>>»
EFTA_R1_01235989
EFTA02322898
>> >
flags
original-mailbox
imap:/ Sent%20Messages
remote-id< key>
4033
2
EFTA_R1_01235990
EFTA02322899
DataSet-10
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2 pages
From:
To: Tyler Shears
Subject: Ny post
Date: Sat, 22 Mar 2014 18:08:01 +0000
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.
On Mar 20, 2014, at 2:19 PM, Tyler Shears
Date: Thu, Mar 20, 2014 at 2:04 PM
Subject: Google Alert - Jeffrey Epstein
To:
7.7
Jeffrey Epstein
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 ...
Ray as irrelevant
G F T
Daily Mall
EFTA00662967
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 ...
G F T
Edit this alert
You have received this email because you have subscribed to Google Alerts.
Unsubscribe I View all your alerts
cliztss Receive this alert as RSS feed
Send Feedback
EFTA00662968
DataSet-10
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1 pages
From:
To:'
Subject: Re: Taylor
Date: Thu, 11 Aug 2011 14:07:13 +0000
Importance: Normal
Ah, so sorry, I got to hotel at midnight, what fax I for this morning? I've got logs with
me,.
Thx
TraveLing LV ;)
Original Message
From:
To: Larry
Subject: Re: Taylor
Sent: Aug 10, 2011 12:20 PM
How fabulous! What an experience for her...and how nice that Daddy got to come in for visits
here and there too!
She may certainly stay until the 20th!
and you can fax the logs to the house (I'm here again now!)
On Aug 10, 2011, at 12:50 PM, wrote:
> Hi III, sorry was driving,. Tay's last day at work is 19th, is it ok with you if she
leaves the apt at noon on the 20th„
> .her summer has been the most amazing NYC adventure a young girl can experience, work was
challenging and fun. I'll fax the logs during my lunch stop, which fax number for logs if I
send in an hour or so?
> Thx
> Larry,.
Original Message
•
> From:
> To: Larry
> Subject: Taylor
> Sent: Aug 10, 2011 11:23 AM
•
> Hey Larry...I actually see 2 different dates in my calendar when it comes to Taylor...I now
recall dates changing a bit...but I don't know what date of her departure is correct...can
you let me know...? I have her departing on the 14th or 19th!! which one is it?
> Let me know! and Let me know when I can get those flight logs so I can get to Delson
•
> Thanks, III :)
> Sent via BlackBerry by AT&T
Sent via BlackBerry by AT&T
EFTA00429408
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2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE
No. 20 Civ. 484 (JOK) (DCF)
Plaintiff,
v.
DARREN INDYKE, et al.,
Defendants.
DECLARATION OF DAVID RODGERS
DAVID RODGERS, declares under penalty of perjury pursuant to 28 U.S.C. §
1746 as follows:
1. I submit this declaration in response to a subpoena dated June 10, 2020, from the
plaintiff in this action, directing me to produce documents and appear for a deposition. I
understand this declaration is being submitted in lieu of appearing for a deposition.
2. Beginning in 1991,1 worked as a pilot for Mr. Jeffrey Epstein ("Epstein") and
Epstein-affiliated entities.
3. Through flying for Mr. Epstein, I met-I do not recall when or
where specifically I for the first time, or the first flight she was on, but it was
likely in the mid to late 1990s.
4. I have attached as Exhibit A my flight logs from the time period between
I made these records at or near the time of the flights reflected
therein, they reflect my knowledge at that time, and it was my practice to regularly make such
records during the 1994-1997 time period. With respect to the names in the "Remarks,
3523-021
Page 1 of 2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009038
EFTA00159197
Procedures, Maneuvers, Endorsements" column, my general practice during this time was to use
this column to record the number of passengers on the plane. If I knew the passenger's name or
had teamed that name during the course of the trip, my general practice was to record that name.
If I did not know or learn the name, I would write down a generic description, for example,
"Baby," "Nanny," "I Male," "1 Female."
5. The first time the name appears in my flight logs between
This entry reflects that a no
last name, was on a flight on that date from
6. also appears in an entry oli This entry reflects that a
no last name, was on a flight on that date from
7. 1 have no specific recollection of either of these flights, which occurred over 23
years ago.
8. I declare under penalty of perjury that the foregoing is true and correct to the best
of my recollection.
Executed on July fl _, 2020
CSIC.C2I&Iti
David Rodgers t ia-
2
3523-021
Page 2 of 2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00009039
EFTA00159198
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1 pages
From: "Meghan McAlpine" <
To: '
Subject: FlightAware will be at NBAA 2015!
Date: Wed, 11 Nov 2015 18:10:01 +0000
Inline-Images: mime_part_l.png; mime_part_2.png; mime_part_3.png; mimefiart_4.png; mime_part_5.png
2FlightAware
My Account My FlightAware
FlightAware at NBAA15! {Schneider Electric Weather with Options
Hello,
EljghtAware is looking forward to seeing you at NBAA as well
as showing you all our exciting new features we have available
that we will be demonstrating!
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multi-continent, altitude and time based premium weather
layers to increase situational awareness during flight dispatch ,Schneider Electric Weather with Options
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turbulence, current and forecast global icing, as well as winds
and temps aloft. These features will help improve flight
planning and safety by increasing weather awareness.
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We will also be displaying aghtAware TV at NBAA.
FlightAware TV displays a large, HDTV, real-time map for
general aviation flights, airline flights or an airport. FlightAware
TV is only USD90 per month, however if you are a current SUB
or Global customer, it is USD45 per month. ; itFlightAware TV
If you are current global customer, you can now add on
premium services from your portal. You have the option to add
an HDTV Map, Premium Weather, Monthly or Annual flight
logs.
Please feel free to email or call me with any questions. Stop by
booth C10326 to see all of our new products or if you have any
questions regarding any of your services.
Meghan McAlpine
Aviation Sales
FlightAware
Direct: 713-622-9989
© 2015 FlightAware. Terms Of Use I &effigy
To discontinue receiveig product announcements from FlightAware. you can unsubscribe
online.
EFTA00335474
DataSet-10
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4 pages
FOIA CONFIDENTIAL TREATMENT REQUESTED /
FED. R. CRIM. P. 6(e) MATERIAL
BSF RESPONSE TO GRAND JURY SUBPOENA
v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y.
Non-Confidential Materials
Jeffrey Epstein Deposition Transcripts (Re: Epstein cases)
April 30, 2009 Epstein Deposition Transcript
GJ SUBPOENA RESPONSE 000002 000159
May 7, 2009 Epstein Deposition Transcript
GJ SUBPOENA RESPONSE 000160 000194
October 8, 2009 Epstein Deposition Transcript
GJ SUBPOENA RESPONSE 000496 000555
February 17, 2010 Epstein Deposition Transcript
GJ SUBPOENA RESPONSE 000852 000919
March 8, 2010 Epstein Deposition Transcript
GJ SUBPOENA RESPONSE 000920 001008
April 4, 2010 Epstein Deposition Transcript
GJ SUBPOENA RESPONSE 001481 001537
Other Witnesses Deposition Transcripts (Re: Epstein cases)
July 29, 2009 Alfredo Rodriguez Deposition Transcript
GJ SUBPOENA RESPONSE 000195 000262
August 7, 2009 Alfredo Rodriguez Deposition Transcript
GJ SUBPOENA RESPONSE 000263 000336
September 8, 2009 Juan Alessi Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 000337 000356
September 8, 2009 Juan Alessi Deposition Transcript (Vol. II)
GJ SUBPOENA RESPONSE 000357 000495
November 23, 2009 Michael Reiter Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 000556 000603
November 23, 2009 Michael Reiter Deposition Transcript (Vol. II)
GJ SUBPOENA RESPONSE 000604 000651
February 16, 2010 Janusz Banasiak Deposition Transcript
GJ SUBPOENA RESPONSE 000652 000851
March 19, 2010 Det. Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 001009 001137
BSF ShareFile Materials
(March 1, 2019)
EFTA00100567
FOIA CONFIDENTIAL TREATMENT REQUESTED /
FED. R. CRIM. P. 6(e) MATERIAL
BSF RESPONSE TO GRAND JURY SUBPOENA
v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y.
Non-Confidential Materials
Other Witnesses Deposition Transcripts (Re: Epstein cases)
March 19, 2010 Det. Deposition Transcript (Vol. II)
001138 001326
GJ SUBPOENA RESPONSE
March 24, 2010 Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 001327 001373
March 24, 2010 Deposition Transcript (Vol. II, III)
GJ SUBPOENA RESPONSE 001374 001442
April 13, 2010 Deposition Transcript
GJ SUBPOENA RESPONSE 001443 001480
Jeffrey Epstein's Jail Visitor Logs (Part 1 and 2)
004331 004467
GJ SUBPOENA RESPONSE
Jeffrey Epstein's Aircraft- Flight Log & Airport Codes
004468 004572
GJ SUBPOENA RESPONSE
Miami Beach Police Report
004573 004581
GJ SUBPOENA RESPONSE
State v. Epstein: E-Materials (CDs) received in response to BSF FOIA Request
State v. Epstein (State Files 1)
➢ Audio and Redacted Control Calls
➢ Walk Through Video
GJ SUBPOENA RESPONSE 004582 004582
State v. Epstein (State Files 2)
➢ Part 1 Audio from Cassettes
GJ SUBPOENA RESPONSE 004583 004583
State v. Epstein (State Files 3)
➢ Part 2 Audio from Cassettes
GJ SUBPOENA RESPONSE 004584 004584
State v. Epstein (State Files 4)
➢ Part 1 Video Interviews
GJ SUBPOENA RESPONSE 004585 004585
State v. Epstein (State Files 5)
➢ Part 2 Video Interviews
GJ SUBPOENA RESPONSE 004586 004586
BSF ShareFile Materials
(March I, 2019)
EFTA00100568
FOIA CONFIDENTIAL TREATMENT REQUESTED /
FED. R. CRIM. P. 6(e) MATERIAL
BSF RESPONSE TO GRAND JURY SUBPOENA
v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y.
Non-Confidential Materials
State v. Epstein: E-Materials (CDs) received in response to BSF FOIA Request
State v. Epstein (State Files 6)
> Part 3 Video Interviews
GJ SUBPOENA RESPONSE 004587 004587
State v. Epstein (State Files 7)
GJ SUBPOENA RESPONSE 004588 004588
State v. Epstein (State Files 7) (CD Contents)
GJ SUBPOENA RESPONSE
➢ State Files 7: Jeffrey Epstein Part 01 redacted 001538 001651
➢ State Files 7: Jeffrey Epstein Part 02 redacted 001652 001782
➢ State Files 7: Jeffrey Epstein Part 03 redacted 001783 001902
➢ State Files 7: Jeffrey Epstein Part 04 redacted 001903 001984
➢ State Files 7: Jeffrey Epstein Part 05 redacted 001985 002109
➢ State Files 7: Jeffrey Epstein Part 06 redacted 002110 002181
➢ State Files 7: Jeffrey Epstein Part 07 redacted) 002182 002276
➢ State Files 7: Jeffrey Epstein Part 08 redacted 002277 002357
➢ State Files 7: Jeffrey Epstein Part 09 redacted 002358 002492
➢ State Files 7: Jeffrey Epstein Part 10 redacted 002493 002594
➢ State Files 7: Jeffrey Epstein Part 11 redacted 002595 002705
➢ State Files 7: Jeffrey Epstein Part 12 redacted 002706 002801
➢ State Files 7: Jeffrey Epstein Part 13 redacted 002802 002905
➢ State Files 7: Jeffrey Epstein Part 14 redacted 002906 003029
➢ State Files 7: Jeffrey Epstein Part 15 redacted 003030 003123
➢ State Files 7: Jeffrey Epstein Part 16 redacted 003124 003223
➢ State Files 7: Jeffrey Epstein Part 17 redacted 003224 003374
➢ State Files 7: Jeffrey Epstein Part 18 redacted 003375 003469
BSF ShareFile Materials
(March 1, 2019)
EFTA00100569
FOIA CONFIDENTIAL TREATMENT REQUESTED /
FED. R. CRIM. P. 6(e) MATERIAL
BSF RESPONSE TO GRAND JURY SUBPOENA
v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y.
Non-Confidential Materials
➢ State Files 7: Jeffrey Epstein Part 19 redacted 003470 003558
➢ State Files 7: Jeffrey Epstein Part 20 redacted 003559 003751
➢ State Files 7: Jeffrey Epstein Part 21 redacted 003752 003835
➢ State Files 7: Jeffrey Epstein Part 22 redacted 003836 004018
➢ State Files 7: Jeffrey Epstein Part 23 redacted 004019 004105
➢ State Files 7: Jeffrey Epstein Part 24 redacted 004106 004330
BSF ShareFile Materials
(March 1, 2019)
EFTA00100570
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5 pages
FILE CABINET ONE
DRAWER ONE:
CMA vs. JEE
Correspondence
Summons and Complaint JEE
Summons and Complaint
Motion, Notice and Order of Dismissal
Rosenfeldt vs. Rothstein
Doe 1 Case # 6596
Doe II Case # 20614 Document Production
Doe II Case # 20614
Jane Doe 8 Case # 80802
Jane Doe 102 Case ft 80656
CMA Casett 80811
AC Case tt 25129
DRAWER TWO:
Josefsberg Invoices and Disc
81092
Doe 2 Case it 80119
Doe 3 Case# 80232
DRAWER THREE
EFTA00299859
Doe 4 Case # 80380
Doe 5 Case # 80381
DRAWER FOUR
Doe 6 Case # 80994
Doe 7 Case #
Jane Doe 101 Case # 80591
FIFTH DRAWER
Jane Doe Case # 80893
Jane Doe II Case # 80469
LM Case # 28051
LM CASE R20851PETITION FOR WRIT OF CERTIORARI AND APPENDIX TO PETITION FOR WRIT OF CERTIORARI (LOCATED IN
A REDWELD ON ITS OWNI) EDWARDS
EW Case # 28058
BB Case # 37319
Case # 80736
Case# 4D09-2254
ON THE FLOOR
Video-Conferenced and Videotaped Deposition of Jane Doe 4, Tues. Oct. 27, 2009 (Volume I of
III, Volume II of III and Volume III of III)
Video-Conferenced and Videotaped Deposition of Dec. 4, 2009 (Volume I
of II and Volume II of II)
EFTA00299860
MJ vs EPSTEIN
-Correspondence
-Attorney's Notes
-Deposition Subpoena to JE
-Pleadings
-Affidavit of Richard Barnett
-Mi's Motion for A Protective Order Barring Direct or Indirect Contact by Epstein
-Mi's Motion for Preservation of Evidence Relating to Correspondence with the US Attorneys Office
-Supplemental Affidavit of Richard Barnett
EPSTEIN VS ROTHSTEIN
-Revised Privilege Log Hilighted by JE
-Dispute Over Production of "Privileged" Documents
-Consent of Plaintiff JE to Motion to Continue Trial
Settlement Agreements (Located on the floor next to file cabinet #1) and
Dismissals
-Video Depositions and DVD that could be used in Brad Edwards Case (SENT THE DVD TO JAY
LEFKOWITZ ON OCT. 14, 2010)
(Signed Settlement)
. (Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(Signed Settlement, Stipulation of Dismissal, Order Adopting Stipulation & Dismissal)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)]
EFTA00299861
(Stipulation of Dismissal, Order Dismissing w/Prejudice)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(M. Case # 81092) (Final Order of Dismissal, Stipulation of Dismissal)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(Stipulation of Dismissal, Order Dismissing Claims and Closing Case)
(Signed Settlement)
(Signed Settlement, Stipultion of Dismissal, Final Order of Dismissal, Order Adopting &
Entering Joint Stipulation)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
Non-NPA (Signed Settlement)
(Signed Settlement)
(Signed Settlement)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
(Signed Settlement)
(Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal)
EFTA00299862
ON TOP OF CABINET
Couturier Correspondence Binder
Flight Log Binders:
Hyperion Manifest 1999 & 2000
Hyperion Manifest 2001 & 2002
Hyperion Manifest 2003-2004
Flight Logs 2009 and 2010
Communications Regarding Jeepers/DB Zwirn 1 of 2
Communications Regarding Jeepers/DB Zwirn 2 of 2
EFTA00299863
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3 pages
From: George Delson
To: Lesley Groff <1
Subject: Re: Jeffrey Epstein
Date: Thu, 10 May 2012 16:36:33 +0000
Everything else looks fine. I will send you the count this afternoon.
The material contained herein is confidential, may be privileged, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited and
may be unlawful. If you have received this communication in error, please notify us immediately, and destroy
same and all copies thereof, including all attachments.
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.
From: Lesley Groff
To: George Delson
Sent: Thursday, May 10, 2012 12:01 PM
Subject: Re: Jeffrey Epstein
super...let me know if anything else is weird!
On May 10, 2012, at 12:00 PM, George Delson wrote:
yes, got it. Thanks.
The material contained herein is confidential, may be privileged, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited and
may be unlawful. If you have received this communication in error, please notify us immediately, and destroy
same and all copies thereof, including all attachments.
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.
From: Lesley Groff
To: George Delson
Sent: Thursday, May 10, 2012 11:57 AM
Subject: Re: Jeffrey Epstein
I am faxing you the flight log for the chartered flight JE took from the ranch to Santa Monica, CA on Feb.
27th...please confirm receipt. thanks!
On May 10, 2012, at 11:19 AM, George Delson wrote:
EFTA00413391
ok, thanks.
The material contained herein is confidential, may be privileged, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited
and may be unlawful. If you have received this communication in error, please notify us immediately, and
destroy same and all copies thereof, including all attachments.
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.
From: Lesley Groff
To: George Delson
Sent: Thursday, May 10, 2012 11:13 AM
Subject: Re: Jeffrey Epstein
that is a great question....I will get back to you!
On May 10, 2012, at 11:03 AM, George Delson wrote:
Lesley-
Thanks! Here's another question. On February 21, Jeffrey flew from NY to Denver and then from Denver to
New Mexico. The next log I have is for Mar 1 from LA to Florida. How and when did he get from New
Mexico to LA?
The material contained herein is confidential, may be privileged, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited
and may be unlawful. If you have received this communication in error, please notify us immediately, and
destroy same and all copies thereof, including all attachments.
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.
From: Lesley Groff
To: George Delson
Sent: Thursday, May 10, 2012 10:49 AM
Subject: Re: Jeffrey Epstein
Hi Joan...so sorry for the confusion...looking back Jeffrey did NOT take the Open Skies flight on the Jan
7th...this flight was cancelled. Jeffrey instead took his own plane on Jan. 8th from Teterboro to Manchester,
NH and then Manchester, NH on to Paris.
Thank you and if you have any more questions, please do ask!
Lesley
On May 10, 2012, at 10:42 AM, George Delson wrote:
EFTA00413392
Lesley-
Can you please clarify the flight logs you sent for January 7 and 8? There is an Openskies booking for JEE
from NY to Paris on Jan 7, arriving Jan 8. Then there is a Hyperion log leaving Teterboro on Jan 8 arriving
Manchester on Jan 8. Then there is another Hyperion log on Jan 8 from Manchester to Paris arriving Jan 9.
They all list JEE as a passenger. This does not seem possible if JEE was in Paris on the first flight arriving
Jan 8??
Thank you.
The material contained herein is confidential, may be privileged, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is
prohibited and may be unlawful. If you have received this communication in error, please notify us
immediately, and destroy same and all copies thereof, including all attachments.
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.
From: Lesley Groff -1
To: George Delson & Associates Delson George
Sent: Thursday, May 10, 2012 8:05 AM
Subject: Jeffrey Epstein
Good morning Maryellen. Could you please do a count of Jeffrey's days so far this year. He is currently
still in NY as the last flight log you have should state..
Please reply back and let me know when we can expect the count.
Thank you,
Lesley
Sent from my iPhone
EFTA00413393
DataSet-10
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28 pages
DRAFT
2/7112 6:30 PM
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION AG
CASE NO. 502009CA040800XXXXMB
Judge David F. Crow
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
v.
SCO"IT ROTIiSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiffs.
PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL
PRODUCTION OF DOCUMENTS FROM DEFENDANT BRADLEY EDWARDS
AND FOR SANCTIONS
Plaintiff, Jeffrey Epstein, by and through his undersigned counsel, hereby respectfully
seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents
listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards
to serve a privilege log that fully complies with Fla. R. Civ. P. 280(b)(5), and an in camera
review of the documents specified below, together with an award of attorney's fees and costs,
and in support thereof would show as follows:
SUMMARY OF ARGUMENT
On or about February 23, 2011, Edwards, in response to several orders entered by Judge
Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege
EFTA01082227
DRAFT
Epstein v. Rothstein 22a 2EMT
Case No. 502009CA040800XXXXMI3/Div. AG
log, claiming that over two thousand (2,000) documents are privileged) This is Edwards'
second privilege log that blatantly fails to meet the requirements for a legally sufficient privilege
log under Fla. R. Civ. P. 1.280 (b)(5), as interpreted by the Fourth District Court of Appeal in
TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). In addition, although the
Special Master required a master list of names contained in the privilege log, a description of the
recipients of the documents, and identification of the individuals who received blind copies,
Edwards failed to provide the names of the individuals who were copied directly or who received
blind copies, and many recipients are insufficiently identified only as "Attorneys at RRA,"
"Staff," and "RRA Personnel.i 2 Edwards' gross failure to comply with Fla. R. Civ. P.
1.280(b)(5) prevents the Plaintiff and the Court from determining whether Edwards has made
any valid privilege assertions and results in a waiver of the privileges claimed. Edwards has not
provided sufficient descriptions of the documents to determine if the privilege(s) claimed are
valid. Finally, Edwards claims privileges that do not exist under Florida law.
ARGUMENT
I. REQUIREMENTS FOR A PRIVILEGE LOG
The requirements for a privilege log in Florida are set forth in Fla. R. Civ. P. 1.280(b)(5),
which provides as follows (emphasis added):
Edwards' privilege log is being filed contemporaneous with the filing of the subject
motion. For ease of reference, excerpts from the log are attached hereto as exhibits.
2After Epstein's Motion to Compel was heard on August 4, 2010, the Bankruptcy Court
entered at least four (4) orders directing Edwards to prepare a privilege log, the last of which
required the privilege log to be completed by January 31, 2011. The first log, served on January
26, 2011, was in woeful noncompliance with the TIG requirements. On February 23, 2011,
another log was served by Edwards which again patently failed to comply with TIG
requirements. The February 23, 2011 log is the subject of the instant motion.
2
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Claims of Privilege or Trial Protection Materials. When a party
withholds information otherwise discoverable under these rules by
claiming that it is privileged or subject to protection as trial
preparation material, the party shall make the claim expressly and
shall describe the nature of the documents, communications, or
things not produced or disposed in a manner that, without
revealing information itself privileged, or protected, will enable
other parties to assess the applicability of the privilege or
protection.
The key case in the Fourth District construing Fla. R. Civ. P. 1.280(b)(5) is TIG Ins.
Corp., 799 So. 2d 339, in which the Fourth District Court of Appeal denied a petition for a writ
of certiorari seeking review of an order requiring TIG, the homeowner's insurer, to produce
documents for which objections on the basis of attorney-client and work-product privileges were
made.
The Fourth District noted in TIG that Rule 1.280(b)(5) is identical to its federal
counterpart, Fed. R. Civ. P. 26(b)(5), whose Advisory Committee Notes state that "to withhold
materials without such notice is contrary to the rule, subjects the party to sanctions under rule
37(b)(2) and may be viewed as a waiver of the privilege or protection." 799 So. 2d at 340. The
TIG court further observed that Local Rule 26.1(G)(3)(b), of the United States District Court,
Southern District of Florida, spelled out the requirements for a valid privilege log, id. at 341:
Where a claim of privilege is asserted in objecting to any
interrogatory or document demand, or sub-part thereof, and an
answer is not provided on the basis of such assertion:
(i) The attorney asserting the privilege shall in the objection to the
interrogatory or document demand, or sub-part thereof, identify the
nature of the privilege (including work product) which is being
claimed and if the privilege is being asserted in connection with a
claim or defense governed by state law, indicate the state's
privilege rule being invoked; and
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(ii) The following information shall be provided in the objection,
unless divulgence of such information would cause disclosure of
the allegedly privileged information:
(A) For documents: (1) the type of document; (2) general subject
matter of the document; (3) the date of the document; (4) such
other information as is sufficient to identify the document for a
subpoena duces tecum, including, where appropriate, the author of
the document, the addressee of the document, and, where not
apparent, the relationship of the author and addressee to each other.
• • •
The Fourth District also quoted with approval from Abbott Laboratories v. Alpha
Therapeutic Corp., 2000 U.S. Dist. LEXIS 20834, at *13 (N.D. III. Dec. 14, 2000), in which the
court stated that a privilege log should:
describe the document's subject matter, purpose for its production,
and a specific explanation of why the document is privileged or
immune from discovery. These categories, especially this last
category, must be sufficiently detailed to allow the court to
determine whether the discovery opponent has discharged its
burden of establishing the requirements expounded upon in the
foregoing discussion. Accordingly, descriptions such as 'letter re
claim,' analysis of claim,' or 'report in anticipation of
litigation'--with which we have grown all too familiar--will be
insufficient. This may be burdensome, but it will provide a more
accurate evaluation of a discovery opponent's claims and takes into
consideration the fact that there are no presumptions operating in
the discovery opponent's favor. Any failure to comply with these
directions will result in a finding that the plaintiff-discovery
opponents have failed to meet their burden of establishing the
applicability of the privilege. (Citations omitted)
Thus, a party invoking a privilege "must...provide sufficient
information to enable other parties to evaluate the applicability of
the claimed privilege or protection." Hoot Winc, LLC v. KIM
McGladrey Fin. Process Outsourcing LLC, 2009 U.S. Dist.
4
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Case No. 502009CA040800XXXXMB/Div. AG
LEXIS 103045, at *9 (S.D. Cal. Nov. 4, 2009) (quoting Advisory
Committee Notes to Rule 26(b)(5)).3
TIG, 799 So. 2d at 341.
II. EDWARDS' PRIVILEGE LOG VIOLATES FLA. R.
CIV. P. 1.280(b)(5) AND THE TIG REQUIREMENTS
Edwards' privilege log clearly violates the requirements of Florida law, and is insufficient
on its face, as first evidenced by Edwards' one hundred and ninety-one (191) attempts to shield
documents from or to an unnamed "confidential source," especially for documents described as
"Litigation Strategy." See Composite Exhibit A as an example.
Second, and no less outrageous, is Edwards' use in approximately 101 ►og entries for
"senders" and "recipients" of the generic terms "attorney and staff," "litigation," "RRA
personnel," and "unknown staff attorneys at RRA." Such generic terms do not meet the TIG
requirements. See Composite Exhibit B as an example. Edwards' numerous references to
unnamed "Attorneys at RRA" are patently inappropriate, if not disingenuous, preventing in each
instance a necessary determination as to whether Edwards has validly invoked a privilege.
Without identification of the particular RRA attorney as the sender or recipient, it is impossible
3 See also Evans v. United Fire & Cas. Ins. Co., 2007 U.S. Dist. LEXIS 58578, at *9
(E.D. La. Aug. 9, 2007) ("United has provided a privilege log, but it is insufficient on its face.
Rule 26(b)(5) requires such a log to 'describe the nature of the documents, communications, or
things not produced or disclosed in a manner that, without revealing information itself privileged
or protected, will enable other parties to assess the applicability of the privilege or protection.' ");
Caplan v. Fellheimer Eichen Braverman & Kaskey, 162 F.R.D. 490, 492 (E.D. Pa. 1995) (party's
failure to explain nature of the assertedly privileged communication precluded court from
determining whether privilege applied); Harper v. Auto-Owners Ins. Co., 138 F.R.D. 655, 664
(S.D. Ind. 1991) (requiring the log to list, for each separate document, the authors and their
capacities, the recipients (including copy recipients) and their capacities, the subject matter of the
document, the purpose for its production, and a detailed, specific explanation of why the
document is privileged or immune from discovery).
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to determine whether Edwards can properly shield the materials from disclosure. Such
non-disclosure strongly suggests a deliberate effort by Edwards to prevent the disclosure of
documents to and from Scott Rothstein, who is rarely named as a sender or recipient.
Third, Edwards' privilege log fails to indicate whether the documents were copied or
distributed to third parties, or whether blind copies were sent to third parties, which the Special
Master required. See Privilege Log generally.
Fourth, the privilege log fails to indicate whether the materials contain attachments.
"Where a privileged document has attachments, each attachment must individually satisfy the
criteria for falling within the privilege. Merely attaching something to a privileged document
will not, by itself, make the attachment privileged." Leonen v. Johns-Manville, 135 F.R.D. 94,
98 (D.N.J. 1990). Edwards is not entitled to invoke a privilege with respect to attachments
which themselves have not been described at all and lack the specificity required to determine
whether any privileges apply. It is hard to fathom that not one of these documents listed in the
log did not have an attachment. So the Court should order attachments produced.
Fifth, it is readily apparent that the privilege log fails to adequately describe over 200
assertedly privileged documents with descriptions such as "in re Epstein," "litigation strategy,"
"Meeting" and "FYI." Such shorthand, cryptic labels, with no description whatsoever of the
content of the materials, do not permit Epstein or the Court to begin to evaluate the applicability
of the privileges claimed by Edwards. TIG, 799 So. 2d at 341 (quoting Abbott Labs, 2000 U.S.
Dist. LEXIS 20834, at *13)("[D]escriptions such as 'letter re claim', 'analysis of claim' or 'report
in anticipation of litigation'.. . will be insufficient.").
6
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Sixth, Edwards' privilege log does not disclose the type of documents that are assertedly
privileged — e.g., email, letter, memo. See Privilege Log generally.
Finally, Edwards' privilege log is grossly inadequate and in blatant violation of Rule
1.280(b)(5), precluding Epstein and the Court from evaluating the applicability of the numerous
privileges claimed.
III. EDWARDS HAS NO VALID PRIVILEGE CLAIMS
A. Edwards Has No "Confidential Source" Privilege
Edwards objects to producing hundreds of pages of documents from or to a purportedly
"confidential source." See as an example Comp. Ex. A. There are at least one hundred and
ninety-one (191) entries in the privilege log that cite a "confidential source." There is no
Florida law, however, that gives Edwards the right to assert a privilege based upon "a
confidential source." Indeed, a "confidential source" privilege applies only with respect to
reporters protecting their sources. See, e.g., CBS v. Jackson, 578 So.2d 698, 700 (Fla. 1991)
(journalists have a qualified privilege against revealing confidential sources of information).
Edwards is not a reporter. Therefore, as a matter of settled law, Edwards has no valid objection
based upon a "confidential source" privilege. The Court should order these documents
produced forthwith.
B. "Privacy Rights"
Edwards objects to the production of approximately 930 documents on the ground that
they are "protected by privacy rights." See Privilege Log generally and Composite Exhibit C,
as an example. Remarkably, Edwards claims that approximately 75% of the documents listed
are shielded from discovery by unspecified "privacy rights." His objections, however, do not
7
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identify the specific "privacy" privilege or describe the person whose privacy interests are
assertedly at stake or the nature of the privacy interest at stake. Such amorphous "privacy
rights" are non-existent under Florida law. No valid privilege can be raised in an attempt to
protect purely generic "privacy rights."
Section 90.501, Fla. Stat., expressly states in relevant part that "[e]xcept as provided by
this chapter, any other statute, or the Constitution of the United States or of the State of Florida,
no person in a legal proceeding has a privilege to . . . (3) [defuse to produce . . . any writing."
Neither the Florida Evidence Code, other Florida statutes, or the Constitution, recognizes a
privilege for generic "privacy rights" or precludes the production of documents in a legal
proceeding based upon a general right of privacy. See La Roche v. Wainwright, 599 F.2d 722,
726 (5th Cir. Ha. 1979) (rejecting "fourteenth amendment rights to privacy" to protect marital
relationship: "[W]e see no persuasive reason to extend the right of privacy, based as it is on
"penumbras and emanations" of other more explicit constitutional rights, to evidentiary matters
protecting marital relationships, long thought to be uniquely within the regulatory province of the
individual states.").
In sum, Edwards cannot hide behind a sham privilege based on "privacy rights."
C. Attorney-Client Privilege Does Not Apply
to Non-Attorney-Client Communications
Edwards invokes the attorney-client privilege with respect to thousands of pages of
documents listed in 120 pages of his 159-page privilege log. See Privilege Log generally.
Significantly, the log describes only three of these documents as attorney-client communication.
See Exhibit D, Bates 02546-02547, 02809-02810, 02807-02808. There is no description or
information provided by Edwards to suggest that any of the other documents claimed to be
8
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Epstein v. Rothstein 22a2Edkjgrig
Case No. 502009CA040800XXXXMB/Div. AG
subject to the attorney-client privilege, actually are. The following examples demonstrate
Edwards' utterly cavalier and improper invocation of the attorney client privilege: 1) Priscilla
Nascimento to "Attorneys at RRA" re: reserving a conference room; 2) Beth Williamson to
Bradley Edwards re: "Discussions about Brad's recovery"; and 3) Bradley Edwards to Carolyn
Edwards re: "Personal Convo between Brad and Mom" See Composite Exhibit E, as an
example. The attorney-client privilege applies only to communications between counsel and
client and cannot be asserted to block the discovery of communications that are not identified as
attorney-client communications. See, e.g.,, §90.502, Fla. Stat., Skorman v. Hovnanian of Florida,
Inc., 382 So. 2d 1376, 1378 (Ha. 4th DCA 1980). Accordingly, no attorney-client privilege
attaches to communications that have not been specifically identified by Edwards as
attorney-client communications.
In addition, with respect to the numerous communications or documents to which
Edwards has asserted the attorney-client privilege, Edwards must establish all of the following
elements: (1) the asserted holder of the privilege is or sought to become a client; (2) the person to
whom the communication was made (a) is a member of a bar of a court, or his subordinate, and
(b) in connection with this communication is acting as a lawyer; (3) the communication relates to
a fact of which the attorney was informed (a) by his client (b) without the presence of strangers
(c) for the purpose of securing primarily either (i) an opinion on law or (ii) legal services or (iii)
assistance in some legal proceeding, and not (d) for the purpose of committing a crime or tort;
and (4) the privilege has been (a) claimed and (b) not waived by the client. See § 90.502, Fla.
Stat.; State v. Rabin, 495 So. 2d 257, 60 (Fla. 3d DCA 1986). The attorney-client privilege
does not apply to communications between an attorney and a third party, or a person who is not a
9
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Case No. 502009CA040800XXXXMB/Div. AG
client. See State v. Rabin, 495 So. 2d at 260 (attorney-client privilege did not attach to
attorney's communication with client's ex-wife). The attorney-client privilege is waived if the
client voluntarily discloses the substance of the communication. See § 90.507, Fla. Stat.; Delap
v. State, 440 So. 2d 1242, 1247 (Fla. 1983) ("[W]hen a party himself ceases to treat the matter as
confidential, it loses its confidential character.").
Edwards' woefully inadequate privilege log does not provide sufficient information to
enable Epstein and the Court to determine the applicability of the attorney-client privilege to the
thousands of communications listed in the privilege log. The alleged client involved is not
disclosed with respect to each communication. The purpose of the document is not described.
The names of all recipients are not disclosed, preventing a determination as to whether the
attorney-client privilege was waived. No information is provided which would enable the
Court and Epstein to determine whether the communications were intended to be disclosed to
third parties or did not involve the giving of legal advice, in which case there is no privilege.
See, e.g., Watkins v. State, 516 So. 2d 1043, 1046 (Fla. 151 DCA 1987).
D. The Work Product Privilege Cannot Be
Determined From Edwards' Privilege Log
Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d
108, 112 (Fla. 1970), explained what is covered by the work product privilege:
[T]hose documents, pictures, statements and diagrams which are to
be presented as evidence are not work products anticipated by the
rule for exemption from discovery. Personal views of the attorney
as to how and when to present evidence, his evaluation of its
relative importance, his knowledge of which witness will give
certain testimony, personal notes and records as to witnesses,
jurors, legal citations, proposed arguments, jury instructions,
diagrams and charts he may refer to at trial for his own
10
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Epstein v. Rothstein 21
E12Ecdr71
Case No. 502009CA040800XXXXMB/Div. AG
convenience, but not to be used as evidence, come within the
general category of work product.
The work product doctrine protects documents and papers of an attorney or a party
prepared in anticipation of litigation, regardless of whether they pertain to confidential
communications between attorney and client. Fla. R. Civ. P. 1.280(b)(2). See Southern Bell
TeL & TeL Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). Work product is a qualified immunity
from discovery. See DeBartolo-Aventlira, Inc. v. Hernandez, 638 So. 2d 988 (Fla. 3d DCA
1994). The work product privilege does not extend to materials intended for use as evidence at
trial. Northup v. Acken, 865 So. 2d 1267 (Fla. 2004).
Work product falls into two categories: 1) "fact" work product consisting of factual
information pertaining to a client's case that is prepared in anticipation of litigation or for trial by
another party; and 2) "opinion" work product, which includes all attorney's mental impressions,
opinions or conclusions about a client's case. The former is discoverable upon a showing of (a)
need for the materials to prepare the party's case, and (b) inability to obtain the substantial
equivalent of such materials without undue hardship. See, e.g., Metric Engineering, Inc. v.
Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003). The latter is subject to nearly absolute
immunity. See, e.g., Smith v. Fla. Power & Light Co., 632 So. 2d 696 (Fla. 3d DCA 1994).
A trial court is instructed "to make particularized findings in support of its determination
of which of the documents are, or are not, subject to the work product privilege." Dismas
Charities, Inc. v. Dobbs, 795 So. 2d 1038, 1039 (Ha. 4th DCA 2001). The party asserting the
privilege must prove that the materials constitute work product. See, e.g., Prudential Ins. Co. of
Am. v. Fla. Dep't of Ins., 694 So. 2d 771, 773-74 (Fla. 2d DCA 1997) (objecting party provided
affidavits stating that the documents were prepared in anticipation of litigation). See, e.g.,
11
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Case No. 502009CA040800X)OCXMB/Div. AG
Lloyds Underwriters of London v. El-Ad Villagio Condo. Ass'n, 976 So. 2d 28 (Ha. 4th DCA
2008) (discovery order quashed where no in camera inspection was made). Thus, a trial court is
not required to protect materials from discovery if a party makes no affirmative showing, and
only makes "a blanket statement that these items were prepared in anticipation of litigation and
are protected from disclosure without presenting evidence to support the claim." Wal-Mart
Stores, Inc. v. Weeks, 696 So. 2d 855, 856-57 (Fla. 2d DCA 1997).
Once the party seeking the documents challenges non-production, the burden shifts to the
opposing party to establish that the materials were prepared in anticipation of litigation in which
case they are discoverable upon a showing that the former has need of the materials and cannot
obtain the equivalent without undue hardship. See, e.g., Tampa Med. Assoc., Inc. v. Estate of
Torres, 903 So. 2d 259, 263-64 (Ha. 2d DCA 2005).
Given the numerous violations on the face of Edwards' privilege log, including no
descriptions of the types of communications, inadequate descriptions of the content of the
communications, and no references to particular clients, Epstein and the Court have no way to
determine whether the work product privileges claimed are fact or opinion work product. See
Privilege Log generally. It is essential that sufficient information be provided by Edwards to
distinguish between fact and opinion work product. The need to ascertain which "facts" are
being protected is particularly critical given the testimony by Scott Rothstein of extensive fraud
at RRA, and Epstein's right to discover fact work product upon a showing of need.
E. Pooled, Joint Defense or Common Litigation
Interest Cannot Be Determined from the Privilege Log
Litigants who share "unified interests" may exchange privileged information to prepare
their case without losing the benefit of the attorney-client interest pursuant to the "joint defense,"
12
EFTA01082238
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Epstein v. arcis
Case No. 502009CA040800XXXXMB/Div. AG
"common interest" or "pooled information" exception. Visual Scene, Inc., v. Pilkington Bros.,
508 So. 2d 437, 440 (Fla. 3d DCA 1987). The exception has been recognized in the case of
co-defendants, co-parties to potential litigation, members of a class of plaintiffs pursuing
separate suits, and defendants in separate actions. Id. (citations omitted).
However, the joint defense privilege, more properly identified as the "common interest
rule," see generally Capra, The Attorney-Client Privilege In Common Representations, 20 Trial
Lawyers Quarterly, Summer 1989, at 20, has been described as an extension of the attorney
client privilege, Waller v. Financial Corp. of Am., 828 F.2d 579, 583 n.7 (9th Cir. 1987). It
serves to protect the confidentiality of communications passing from one party to the attorney for
another party where a joint defense effort or strategy has been decided upon and undertaken by
the parties and their respective counsel. See United States v. Bay State Ambulance and Hosp.
Rental Serv., 874 F.2d 20, 28 (1st Cir. 1989). Only those communications made in the course
of an ongoing common enterprise and intended to further the enterprise are protected.
Eisenberg v. Gagnon, 766 F.2d 770, 787 (3d Cir.), cert. denied, 474 U.S. 946, 106 S. Ct. 342, 88
L. Ed. 2d 290 (1985); Matter of Bevil!, Bresler & Schulman Asset Management Corp., 805 F.2d
120 (3d Cir. 1986). United States v. Schwimmer, 892 F.2d 237, 243 (2d Cir. N.Y. 1989)
(emphasis added). Thus, "parties seeking to invoke the exception must establish that they
agreed to engage in a joint effort and to keep the shared information confidential from outsiders."
Ken's Foods, Inc. v. Ken's Steak House, Inc., 213 F.R.D. 89, 93 (D. Mass. 2002). See also
United States v. Sawyer, 878 F. Supp. 295, 297 (D. Mass. 1995) (despite similar interests
between employer and employee, there was insufficient evidence that communications were
13
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made during the course of a joint defense effort; proponent could not establish the time frame of
the purported agreement or the acts creating and/or terminating the agreement).
Edwards' privilege log does not establish that the communications listed were made
during the course of an "ongoing common enterprise," does not establish relevant time frames,
and does not establish that "a joint defense effort or strategy has been decided upon and
undertaken by the parties and their respective counsel." North River Ins. Co. v. Columbia
Casualty Co., 1995 U.S. Dist. LEXIS 53, at *7 (S.D.N.Y. Jan. 5, 1995) (citation and quotation
omitted).
Given the critical gaps in Edwards' privilege log, it is impossible to determine whether
Edwards can properly invoke the "common interest" doctrine to preclude discovery.
IV. EDWARDS' FAILURE TO SUPPLY AN ADEQUATE
LOG WAIVES THE PRIVILEGES CLAIMED AND
SUPPORTS SANCTIONS AGAINST EDWARDS
It is settled that the failure to supply a privilege log which complies with Florida law
results in the waiver of a privilege under Florida law. TIG, 799 So. 2d at 341 ("Any failure to
comply with these directions will result in a finding that the plaintiff-discovery opponents have
failed to meet their burden of establish[ing] the applicability of the privilege."). The TIG court
noted that Rule 1.280(B)(5) "uses mandatory language, and federal courts have found waiver
where the federal rule was violated." Id. (citing cases). The TIG court concluded that there was
no departure from the essential requirements of the law in compelling production based upon a
privilege waiver: "Because the trial court did not have the benefit of specific descriptions of the
documents, we assume that the court found a waiver." Id. at 342. See also Century Bus.
Credit Corp. v. Fitness Innovations & Techs., Inc., 906 So. 2d 1156. 1157 (Fla. 4th DCA 2005)
14
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Case No. 502009CA040800XXXXMB/Div. AG
(the court denied a petition for certiorari directed to an order finding a waiver of privilege in
regard to the production of documents because the petitioner filed a privilege log which was
"completely inadequate"); Kaye Scholer LLP v. Zalis, 878 So. 2d 447, 449 (Fla. 3d DCA 2004)
(the purpose of the privilege log requirement is "to identify materials which might be subject to a
privilege or work product protection so that a court can rule on the 'applicability of the privilege
or protection' prior to trial...Failure to comply with the requirements of Rule 1.280(6)(5) results
in the waiver of any attorney-client and work-product privileges."); Omega Consulting Group v.
Templeton, 805 So. 2d 1058, 1060 (Fla. 4th DCA 2002) (noting that where a privilege log "filed
by the corporations did not contain sufficient detail to comply with the requirements of Florida
Rule of Civil Procedure 1.280(b)(5)," the attorney-client privilege may be waived).
Edwards has had ample opportunities to file a proper privilege log, and has declined to do
so. Given his blatant violation of Rule 1.280(b)(5), the magnitude of the deficiencies in his
privilege log, and his cavalier invocation of numerous clearly inapplicable and/or non-existent
privileges, this Court should enter an order finding a waiver and requiring production of the
documents requested. See TIG.
In the alternative, the Court should compel Edwards to produce a privilege log that
strictly complies with TIG and the requirements of Rule 1.280 in order that Epstein and the Court
can reasonably determine whether any valid privileges have been asserted and were not waived.
At a minimum, and as soon as convenient, the Court should conduct an in camera
inspection of the documents referenced in ¶¶ 20, 22-4 of the Corrected Second Amended
Complaint and determine whether any of the privileges asserted by Edwards to block the
production of these highly relevant materials are valid or have been waived. These materials -
15
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Case No. 502009CA040800XXXXMB/Div. AG
approximately thirty (30) emails — were sent to or from Edwards during the critical period of
May to October, 2009, when the Ponzi scheme was imploding. The critical nature of these
documents is vividly demonstrated by Rothstein's testimony during his recent deposition that he
had asked Edwards or Adler to specifically set aside a flight manifest for an Epstein private jet.
(Tr. Rothstein Depo 12/21/11 at 2278). Rothstein further testified that he showed boxes with
Epstein files to the Discala investors in his office, disclosing the actual names of the parties "as a
way of me attempting to induce them to invest further." (Tr. Rothstein Depo 12/20/11 at 1917;
see also Tr. 12/21/11 at 2278). Rothstein explained with regard to Edwards' lawsuits that "this
was a big ticket because there was the defendant and he's a wealthy guy" and was associated with
public figures who did not want their names dragged through the mud. (Tr. Rothstein Depo
12/21/11 at 2283).4 'thus, because the documents specifically referenced in the Corrected
Second Amended Complaint are critical to the continued deposition of Rothstein in June, 2012,
an in camera inspection should be conducted of those documents prior to that time, although
Epstein does not hereby waive the right to an in camera review with respect to any of the other
materials referenced in the Privilege Log.
Finally, the actual prejudice to and impact on Epstein by Edwards' willful and continued
non-compliance is palpable. Epstein has been prejudiced because he has not been able to
conduct critical discovery necessary for the prosecution of his claims, and necessary for
It is important to note that in light of Rothstein's testimony, potentially relevant entries
during this time frame — including, Edwards to "Attorneys at RRA" re: "Flight logs for Epstein,"
Bradley Edwards to "Attorneys at RRA" re: "Subpoena Clinton," Bradley Edwards to "Attorneys
at RRA" re: "Investigation Epstein's planes," Bradley Edwards to "Attorneys at RRA" re:
"Epstein meeting," and Priscilla Nascimento to ""Attorneys at RRA" re: "Epstein's Conference
Room Reserved" — raise disturbing questions as to whether the "Attorneys at RRA" designation
used by Edwards in his log is meant to disguise communications to Rothstein.
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Epstein v. Rothstein 21anTEMT
Case No. 502009CA040800XXXXMB/Div. AG
opposition to Edwards' summary judgment motion. Epstein has spent tens of thousands of
dollars in attorney's fees trying to obtain the requested documents from Edwards and address
privilege log issues. Sanctions should be imposed on Edwards to prevent unfair prejudice to
Epstein and to insure the integrity of the discovery process. See Aztec Steel Company v.
Florida Steel Corp., 691 F. 2d 480, 482 (11th Cir.1982).
In sum, pursuant to Fla. R. Civ. P. 1.280, this Court should enter an Order finding that
Edwards' privilege claims are waived, requiring Edwards to produce the documents requested by
Epstein, and requiring Edwards to pay the reasonable expenses incurred by Epstein, including
attorney's fees, costs, payments to the Special Master caused by Edwards' failure to provide a
timely and legally sufficient privilege log, and granting such other and further relief as the Court
deems necessary and proper.
Respectfully submitted,
Joseph L. Ackerman, Jr.
Florida Bar No. 235954
FOWLER WHITE BURNE'FT, P.A.
901 Phillips Point West
777 South Flagler Drive
West Palm Beach Florida 33401
Telephone: 1
Facsimile:
Attorneys for Plaintiff Jeffrey Epstein
and
Christopher E. Knight
Florida Bar. No. 607363
FOWLER WHITE BURNETT, P.A.
Espirito Santo Plaza, 14th Floor
1395 Brickell Avenue
Miami, Florida 33131
Telephone: I
Facsimile:
Attorneys for Plaintiff Jeffrey Epstein
17
EFTA01082243
DRAFT
Epstein v. Rothstein 2gla2Fair PC
Case No. 502009CA040800XXXXMB/Div. AG
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
electronic mail and U.S. Mail on this day of February, 2012 to: Jack Scarola, Esq.,
Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm
Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Wciss, P.A., 250
Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq.,
Law Offices of Marc S. Nurik, One East Broward Blvd., Suite 700, Fort Lauderdale, FL 33301.
Joseph L. Ackerman, Jr.
18
EFTA01082244
Privilege Log — Dated 2-23-2011
Farmer.Jaffe, Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
discovery of admissible evidence
05693-05695 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05698 08/21/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05706-05709 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05720-05721 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05738-05739 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05743-05745 05/29/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05754 08/03/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05759-05762 06/01/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Prlv.; not reasonably calculated to lead to
discovery of admissible evidence
05765-05768 06/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05771-05773 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05777-05779 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05784-05786 06/03/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05791-05794 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to
Epstein Molestations discovery of admissible evidence
05803 07/22/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05836-05837 07/08/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05842-05843 07/08/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
49
EFTA01082245
Privilege Log — Dated 2-23-2011
Farmer, Jaffe. Weissing, Edwards, Fistos & Lehrman
BATES DATE TO FROM DESCRIPTION OBJECTION
05848 07/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05852-05853 07/29/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to
discovery of admissible evidence
05857-05858 07/31/2009 Bradley Edwards Confidential Source Litigation St
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From: Lesley Groff <1
To: George Delson
Subject: Re: Jeffrey Epstein
Date: Fri, 16 Mar 2012 13:56:05 +0000
thank you. have a great weekend
On Mar 16, 2012, at 9:52 AM, George Delson wrote:
Hi Lesley:
Yes I did receive it. Thank you.
Mary Ellen
The material contained herein is confidential, may be privileged, and is intended only for the use of the
addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited and
may be unlawful. If you have received this communication in error, please notify us immediately, and destroy
same and all copies thereof, including all attachments.
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.
From: Lesley Groff •z >
To: George Delson & Associates Delson George •r >
Sent: Thursday, March 15, 2012 12:28 PM
Subject: Jeffrey Epstein
Hi Mary Ellen...I just sent you another flight log for JE...can you please confirm receipt?
Thanks, Lesley
EFTA00417588
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3 pages
From:
To: Ann Rodriquez
Subject: Re: Jeffrey Epstein
Date: Wed, 09 Apr 2014 10:48:10 +0000
good deal...thanks
On Apr 9, 2014, at 6:44 AM, Ann Rodriquez < > wrote:
Wifi assword:
Ann R.
On Apr 9, 2014, at 6:41 AM, Lesley Groff MIMIlle wrote:
I don't know th answer!?
Sent from my iPhone
Begin forwarded message:
From: "Greg Wyler" <
Date: April 9, 2014, 3:23:19 AM EDT
To: Lesley Groff , Jeffrey Epstein
Subject: Re: Jeffrey Epstein
Reply-To:
Is the WiFi available to guests here on the island? If so, what is the password? On Apr 8, 2014 2:19 PM,
Lesley Groff < wrote:
tremendous. thanks
On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote:
My cell is:
See you soon.
Original Message
EFTA00371338
From: Lesley Groff [mailto:
Sent: Tuesday, April 08, 2014 7:36 AM
To:
Cc: Larry Visoski
Subject: Re: Jeffrey Epstein
Hi Greg...come to the house! That will be perfect. Jeffrey has changed wheels up time from Teterboro to
7pm tonight...
Jeffrey's home address:
9 East 71st Street Between 5th and Madison
Is your cell number
If you need to call me:
Thanks for the info!
Lesley
On Apr 8, 2014, at 10:13 AM, Greg Wyler wrote:
Gregory mane Wyler
I can go to necker anytime, 3:30pm departure is fine.
He asked me to come to the house, which was my plan.
EFTA00371339
I land at 3:17 at JFK, and have a car waiting for me. Sitting up front and no bags so I am guessing I
would be there around 4:15.
I can drive straight to teterboro if needed. Will email when I am in the car. On Apr 8, 2014 7:08 AM,
Lesley Groff wrote:
Hello Greg...Jeffrey says you would like a ride tonight on his plane to St. Thomas...He also has kindly
offered you a ride in his helicopter over to Branson's island tomorrow...He did want to make sure you
know he will need you off island by at latest 4pm tomorrow and hope that works with your schedule....
Wheels up from Teterboro tonight is 6pm...Did you and Jeffrey discuss riding together to
Teterboro?...please let me know any details...
We will need your full name as it appears on your ID please for our flight log/pilot.
Thank you,
Lesley
Assistant to Jeffrey Epstein
EFTA00371340
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2 pages
From: Lesley Groff wrote:
•
> Is the WiFi available to guests here on the island? If so, what is the password? On Apr 8,
2014 2:19 PM, Lesley Groff .‘Z > wrote:
> tremendous. thanks
> On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote:
>> My cell is: +1 772 485 9368
>>
» See you soon.
>>
>> Original Message
>> From: Lesley Groff [mailto:
>> Sent: Tuesday, April 08, 2014 7:36 AM
>> To:
>> Cc: Larry Visoski
>> Subject: Re: Jeffrey Epstein
>>
>> Hi Greg...come to the house! That will be perfect. Jeffrey has changed wheels up time
from Teterboro to 7pm tonight...
>> Jeffrey's home address:
>>
» 9 East 71st Street Between 5th and Madison
>>
>> Is your cell number:
>> If you need to call me:
>>
>> Thanks for the info!
» Lesley
>>
>>
>> On Apr 8, 2014, at 10:13 AM, Greg Wyler wrote:
>>
>>>
>>>
>>> Gregory Thane Wyler
>>>
>>> I can go to necker anytime, 3:30pm departure is fine.
>>>
>>> He asked me to come to the house, which was my plan.
>>>
>>> I land at 3:17 at JFK, and have a car waiting for me. Sitting up front and no bags so I
am guessing I would be there around 4:15.
>>>
>>> I can drive straight to teterboro if needed. Will email when I am in the car. On Apr 8,
2014 7:08 AM, Lesley Groff < > wrote:
>>> Hello Greg...Jeffrey says you would like a ride tonight on his plane to St. Thomas...He
EFTA00371341
also has kindly offered you a ride in his helicopter over to Branson's island tomorrow...He
did want to make sure you know he will need you off island by at latest 4pm tomorrow and hope
that works with your schedule....
>>>
>>> Wheels up from Teterboro tonight is 6pm...Did you and Jeffrey discuss riding together to
Teterboro?...please let me know any details...
>>>
>» We will need your full name as it appears on your ID please for our flight log/pilot.
>>>
>»
>» Thank you,
>» Lesley
>» Assistant to Jeffrey Epstein
>»
>»
»
»
>
>
EFTA00371342
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From: Lesley Groff Great Greg,
> Welcome aboard !
> Look fwd to seeing you again,
> All the best
> Larry
•
> Thx Lesley for the heads up.
> Sent from my iPhone
>> On Apr 8, 2014, at 10:13 AM, "Greg Wyler" < > wrote:
>>
>>
>>
>> Gregory Thane Wyler
>>
>> I can go to necker anytime, 3:30pm departure is fine.
>>
>> He asked me to come to the house, which was my plan.
>>
>> I land at 3:17 at JFK, and have a car waiting for me. Sitting up front and no bags so I am
guessing I would be there around 4:15.
>>
>> I can drive straight to teterboro if needed. Will email when I am in the car. On Apr 8,
2014 7:08 AM, Lesley Groff < wrote:
>> Hello Greg...Jeffrey says you would like a ride tonight on his plane to St. Thomas...He
also has kindly offered you a ride in his helicopter over to Branson's island tomorrow...He
did want to make sure you know he will need you off island by at latest 4pm tomorrow and hope
that works with your schedule....
>>
>> Wheels up from Teterboro tonight is 6pm...Did you and Jeffrey discuss riding together to
Teterboro?...please let me know any details...
>>
>> We will need your full name as it appears on your ID please for our flight log/pilot.
>>
>>
>> Thank you,
>> Lesley
>> Assistant to Jeffrey Epstein
>>
>>
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