To: Jeffrey EpsteinDeevacation©gmail.com] From: story cowles Sent Fri 10/23/2009 2:29:58 PM Subject: Zalis I just spoke to Jessica who informed me that the judge denied the protective order that was filed for Zalis. Her deposition will move forward on Tuesday. EFTA_R1_01512007 EFTA02438698
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028051)OMMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF' PLEASE TAKE NOTICE that plaintiff, M., will take the video deposition by oral examination, of the persons named below, at the time, on the date, at the hour of the place indicated: NAME DATE AND PLACE OF TAKING DEPOSITON TIME June 15, 2010 @ I t Ili nt Offi 10:00AM upon oral examination before Videographer and a Notary Public, or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The depositions are being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the Rules of Court. EFTA00612136 CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this I) , day of May 2010 via U.S. Mail and email transmittal to all those on the attached service list. Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman By: Florida Bar No.: 542075 SERVICE LIST Robert D. Critton, Jr. BURMAN, CRITTON, et al. Jack Alan Goldberger, Esq. Atterbu Goldber er et al. Jay Howell, Esq. EFTA00612137
Page 1 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 08-3720CF10A JUDGE: LEVENSON STATE OF FLORIDA CERTIFIED COPY -vs- MICHAEL BILOTTI, Defendant. DEPOSITION OF MICHAEL KADOSH Thursday, April 30, 2015 2:14 p.m. - 3:31 p.m. BROWARD COUNTY COURTHOUSE 201 Southeast Sixth Street Room 670 Fort Lauderdale, Florida 33301 Reported By: SANDRA D. SUAREZ, Court Reporter Notary Public, State of Florida Bailey & Associates Reporting, Inc. Fort Lauderdale, Florida Phone - (954) 358-9090 Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128435 Page 2 APPEARANCES: 2 ON BEHALF OF THE STATE: MICHAEL J. SATZ, STATE Attorney 3 BY: GREGG ROSSMAN, Esquire SASHA SHULMAN, Esquire 4 ASSISTANT STATE ATTORNEY 201 Southeast Sixth Street 5 Fort Lauderdale, Florida 33301 (954) 831-8029 6 7 ON BEHALF OF MICHAEL BILOTTI: FRED HADDAD, Esquire a TARLIKA NAVARRO, Esquire HADDAD & NAVARRO, PLLC 9 ,One Financial Plaza Suite 2612 10 Fort Lauderdale, Florida 33394 (954) 467-6767 ON BEHALF OF CHRISTIN BILOTTI: J. DAVID BOGENSCHUTZ, Esquire 13 BOGENSCHUTZ, DUTKO, DROLL, P.A., 600 South Andrews Avenue 14 Suite 500 Fort Lauderdale, Florida 33301 15 (954) 764-2500 16 ON BEHALF OF JOHN PACCHIANA H. DOHN WILLIAMS, Esquire 17 DOHN WILLIAMS, P.A. 500 Southeast Sixth Street 18 Fort Lauderdale, Florida 33301 (954) 831-8866 19 20. 21 22 23 24 25 Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128436 Page 3 1 INDEX 2 WITNESS: PAGE: 3 MICHAEL KADOSH 4 DIRECT EXAMINATION BY MR. HADDAD: 4 DIRECT EXAMINATION BY MR. WILLIAMS: 61 5 DIRECT EXAMINATION BY MR. BOGENSHUTZ: 66 CROSS-EXAMINATION BY MR. ROSSMAN: 82 6 FURTHER DIRECT EXAMINATION BY MR. HADDAD: 91 7 8 9 NO EXHIBITS MARKED 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128437 Page 4 1 Deposition taken before Sandra D. Suarez, 2 Court Reporter and Notary Public in and for the State of 3 Florida at Large, in the above cause. 4 5 Thereupon, 6 MICHAEL KADOSH, 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: I do. 10 DIRECT EXAMINATION 11 BY MR. HADDAD: 12 Q. What's your name, please? 13 A. Michael Kadosh. 14 Q. Okay. 15 MR. ROSSMAN: K-A-D-O-S-H, correct? 16 THE WITNESS: Yes. 17 BY MR. HADDAD: 18 Q. I know you live down in Miami somewhere, 19 correct? Do you live in Miami? 20 A. Yes, I do. 21 Q. Okay. How long have you been in Miami? 22 A. Since 1979. 23 Q. '79? 24 A. Yes. 25 Q. Okay. And you came from Montreal? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128438 Page 5 A. No. 2 Q. From where? 3 A. I came from New York. 4 Q. Okay. I don't want to go through too much 5 background, because I read all your stuff within the 6 reports. 7 You own some hotels still? 8 A. Yes. 9 Q. And you're a rabbi? 10 A. Yes. 11 Q. And you taught college? 12 A. Yes. 13 Q. Where did you teach college? 14 A. In rabbinical college in Brooklyn. 15 Q. Rabbinical college? 16 A. Uh-huh. 17 Q. I think Jackie Mason was a rabbi, isn't he? 18 A. His brother was. 19 Q. His brother was. That's right, he's a cantor. 20 A. Yeah. 21 Q. I like Jackie Mason, that's the only Jewish I 22 know. 23 A. Cantor make more money than rabbi. 24 Q. Do they? 25 A. Yeah. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128439 Page 6 Q. You did pretty good. It's like you're 2 Catholic or something. 3 A. Yeah. 4 Q. Any rate, you're here today -- obviously, you 5 know why you're here. 6 A. Yes. 7 Q. Okay. So let me ask you a question. I read 8 all of this stuff. How did you end up with the cops? 9 A. Somebody called me, a detective that said that 10 they saw me with Bilotti and they want to talk to me. 11 Q. Okay. Now, do you recall, because this 12 statement that you gave -- did you review this at all 13 before you came here? 14 A. No. 15 Q. Okay. Well, you gave a whole long statement 16 to Yager with Titone there. 17 A. Yes. 18 Q. Okay. Now, do you recall when it was that you 19 gave this statement? 20 A. Yes. 21 Q. What year? 22 A. A couple years ago. I don't remember the 23 exact date, no. 24 Q. Okay. Is there anything that you possess that 25 would refresh your recollection, like, a diary, notes? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128440 Page 7 1 A. No. 2 Q. So we just know a couple years ago you went. 3 A. They called me -- 4 Q. Yager called -- 5 A. -- and they told me to come in and I went. 6 Q. Is that when you hired Titone? 7 A. Well, I called him, and he said I should be 8 with you. 9 Q. Had you hired him before that? 10 A. Yeah, he was my lawyer for long time. 11 Q. All right. There is a $1,000 check running 12 around somewhere. Is that what he charged you to go to 13 this thing? 14 A. No. I don't know what it was for. No idea. 15 Who the check was for, I don't remember. 16 Q. I don't know. Mike Bilotti gave you a check 17 for a $1,000 made out to Joe Titone. 18 A. From Mike Bilotti's account? 19 Q. I -- 20 A. There was our business. I don't know. 21 Q. Yeah, but I mean it was for Joe Titone. 22 A. Yeah, but I don't know what it was for. 23 Q. You don't remember what it was for? 24 A. No. 25 Q. Could it have been for this? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128441 Page 8 A. No. 2 Q. You don't think so? 3 A. No. 4 Q. You use Titone for other stuff? 5 A. Yes. 6 Q. I don't want to get into for whatever else, 7 but 8 A. Mostly civil cases, disputes in business. 9 Q. Okay. Now, you go to the police -- did you go 10 to them or did they come to you? 11 A. No, I had to go to them. 12 Q. Okay. Well, in the beginning of this 13 statement that you give, you and Titone are talking 14 about the Turks, Mike Bernstein, a whole bunch of other 15 stuff. Who was listening in to your conversation? Why 16 is this recorded? 17 A. I don't know. 18 Q. Were you wearing a wire? 19 A. No, I wasn't wearing any wire. 20 Q. All right. Was Titone wearing a wire? 21 A. Not that I know if. 22 Q. Not on his head, I guess, but you don't know 23 if he's wearing a wire? 24 A. No, I don't think so. 25 Q. Okay. And were you sitting in a police Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128442 Page 9 1 station room when this was occurring? 2 A. In a small room in the police station. 3 Q. So apparently the cops must have wired the 4 room and didn't tell you? 5 A. I have no idea. I don't know. 6 Q. And you never read any of this or saw this 7 before? 8 A. I did not. 9 Q. Okay. Because Titone is saying to you, "you 10 know, and when you first got sued by O'Hanna, I tried to 11 sit down with them -- " and you say -- he says, no. And 12 Titone said, "fuck you, we're gonna get $200,000." I 13 said, okay. And Titone said, "they're vicious people." 14 Does that recall any recollection to you? 15 Who is O'Hanna? 16 A. O'Hanna was a kid that used to work for me, 17 and he claims he was my partner. And he was running a 18 hostile, and then at the end, the case was dismissed. 19 Q. Okay. 20 A. He represented me. 21 Q. It was also the guy that killed Bruce Lee's 22 sister in Enter the Dragon. 23 A. Oh, I don't know. 24 Q. A little piece of Triva. 25 All right. So at any rate, all of these Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128443 Page 10 conversations are secretly recorded, as far as you know? 2 A. No. No, I don't know. 3 Q. Well, that's what I'm asking you. You didn't 4 know these were recorded conversations. 5 Do you know how long you were there before the 6 cops came in to see you? 7 A. How long -- 8 Q. How long you were sitting in a room? 9 A. I don't remember. 10 Q. Do you know whether or not, you and Titone, in 11 this recorded room had any conversations regarding Mike 12 Bilotti that may not have been in the transcript? 13 A. I don't remember. 14 Q. Okay. Do you know -- let me put it this way. 15 When you came here, we subpoenaed -- they gave your name 16 as a witness, which doesn't matter, but I subpoenaed 17 you, like, last week. 18 A. I got the subpoena. 19 Q. Yeah, I know. To come in and testify. 20 Has the prosecutors or the state, the cops, 21 anybody given you anything to refresh your recollection, 22 tapes, papers, anything -- 23 A. No. 24 Q. -- about this statement that you gave? 25 A. No. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128444 Page 11 1 Q. All right. And without being too personal, 2 you are undergoing some health issues, correct? 3 A. Yes. 4 Q. I know you're going through dialysis. 5 A. Yes. 6 Q. I think I read somewhere that you have heart 7 issues. 8 A. Uh-huh. 9 MR. WILLIAMS: Is that's a "yes"? 10 THE WITNESS: Yes. 11 BY MR. HADDAD: 12 Q. Now, how old are you, 70-something? 13 A. Seventy-four. 14 Q. Do you have any other issues? 15 A. Health issues. 16 Q. All health issues. Any re memory [sic] 17 issues -- not re memory, any memory issues? Alzheimer? 18 A. No. 19 Q. Dementia? 20 A. No. 21 Q. No. Okay. 22 All right. Now, in this tape, the police say 23 that they have an ongoing investigation where they've 24 continually seen you with Bilotti, do you recall that? 25 A. Yeah. They said they saw me with Bilotti, Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128445 Page 12 yes. 2 Q. And they also said that they picked up 3 conversations with you and Bilotti regarding -- that may 4 involve a murder. Do you recall that, that the cops 5 told you that? 6 A. No. I don't recall that. 7 Q. I'm sorry. 8 A. I don't recall that. 9 Q. All right. Did they ever play for you any 10 tapes or any conversations? 11 A. Not that I remember. 12 Q. Okay. Did they ever tell you whether or not 13 you were picked up on a wiretap? 14 A. Did not. 15 Q. Okay. That was ongoing. 16 A. I don't know. 17 Q. You don't know? 18 All right. Did they ever -- let me put it 19 this way: Did you ever receive a Title III Notice from 20 the federal government at any point within the years of 21 this investigation, advising you that you had been 22 intercepted on a wiretap that was up and going by the 23 feds? 24 A. No. 25 Q. A notice? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128446 Page 13 A. A notice in writing, I never saw. 2 Q. Yeah, a letter. It says, hey, you were 3 intercepted. 4 A. No, I didn't. 5 Q. All right. Because they said, We wanted to 6 give you an opportunity to discuss with us things that 7 may have been discussed by Mr. Bilotti -- you and 8 Mr. Bilotti, particularly concerning a couple of murders 9 that have been mentioned. 10 This is the first time that you ever seen 11 these cops, correct? 12 A. The cops in Davie, yes. 13 Q. Yeah. I mean, you didn't call and say, hey, I 14 got information about -- 15 A. No. No. They called me. 16 Q. They called you. 17 A. We saw you with him. We want to talk to you. 18 I didn't want to go. They said, you have to come. 19 Q. Yeah, I understand that. 20 Do you know how they knew that you had 21 conversations with Bilotti regarding murders? 22 A. I don't know. 23 Q. All right. You don't recall what year you 24 gave this statement, correct? 25 A. I don't. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128447 Page 14 Q. Were you ever aware of whether or not you were 2 under a federal investigation? 3 A. No, I'm not. 4 Q. You weren't? 5 A. Not that I know of. 6 Q. Okay. Well, my understanding is that, this 7 statement was not given over for a number of years 8 because some federal prosecutor asked the state not to 9 give this over, are you aware of that? 10 A. No. 11 MR. ROSSMAN: Are you talking about, you guys 12 getting the -- 13 MR. HADDAD: Yeah. 14 MR. ROSSMAN: No, that was in reference to 15 Bilotti. 16 MR. HADDAD: I don't care. We didn't get it. 17 That's what I'm saying. 18 MR. ROSSMAN: I'm answering your question. 19 They directed me that they had ongoing stuff on 20 Bilotti. And I had told them, you need to tell me 21 what you've got to tell me, fish or cut bait, 22 because I've got to give it out in the state case. 23 MR. HADDAD: Yeah, but it was a couple years 24 later you gave it up. 25 MR. ROSSMAN: Yeah, because they were Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128448 Page 15 directing me that I would be impeding their 2 investigation. 3 MR. HADDAD: I don't give a rat's ass what 4 they directed to you. It was a couple years later 5 before we found out. Well, I'll file a motion to 6 find it, but -- 7 BY MR. HADDAD: 8 Q. Do you know who the feds were that were 9 investigating Bilotti? 10 A. No. 11 Q. Okay. Do you know whether or not Yedick [sic] 12 was being investigated also? The banker, what's his 13 name? 14 A. Zedeck. 15 Q. Zedeck. Zedeck -- Yedick whatever. 16 You don't know? 17 A. No. 18 Q. All right. Has anyone, other than the Davie 19 police, come to you to speak to you about Mr. Bilotti, 20 Mr. Zedeck, anyone? 21 A. Yes. 22 Q. Who? 23 A. I don't know their name. 24 Q. Well, who are they with? 25 A. FBI and FDIC. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128449 Page 16 1 Q. FDIC. So FDIC has got something to do with 2 banks. 3 A. Uh-huh. 4 Q. FBI usually has something to do with white 5 collar issues. So it was some kind of fraud? 6 A. They thought. Yes, I think so. 7 Q. Did you go and talk to the cops about that? 8 A. No, I didn't. 9 Q. You never went before a grand jury? 10 A. No. 11 Q. Did you ever go to the US attorney's office to 12 talk about anything? 13 A. No. 14 Q. Nothing at all? 15 A. They came to me. 16 Q. Okay. Well, let me put it this way: Did 17 anybody come and sit down with you from the FBI, US 18 Attorney's Office and others? 19 A. I believe it was -- I don't remember exactly 20 what, FBI or FDIC together. 21 Q. How long did they speak to you? 22 A. A couple hours. 23 Q. And what did they discuss with you? 24 A. About my dealings with the bank, Bilotti and 25 everything. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128450 Page 17 1 Q. Was that after your talked to these guys from 2 Davie or before? 3 A. I believe it was after. 4 Q. All right. And did they ever show you a copy 5 of the statement or anything else after that? 6 A. No. 7 Q. Did they ever suggest to you, you might be a 8 witness in a federal prosecution? 9 A. No. 10 Q. Did you ever suggest to them that you were 11 aware of criminal activity that was going on with 12 Zedeck, Bilotti or anyone else? 13 A. I just answered whatever questions they asked. 14 They know everything. 15 Q. Did they ask questions about -- 16 MR. WILLIAMS: Whoa. Whoa. You said, they 17 know everything? 18 MR. HADDAD: I understand. 19 THE WITNESS: Yeah, they basically asked me, 20 how did I get to know Bilotti. What kind of loan I 21 made? Do I have the documents? 22 I said, not right now. And how did Bilotti 23 become my partner. And about Zedeck, and I told 24 what I know. 25 Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128451 Page 18 BY MR. HADDAD: 2 Q. You sound like Jackie Mason when you start 3 talking a little faster. 4 A. I like to be like him. 5 Q. At any rate, did they ask you anything with 6 Bilotti regarding the violence that you asserted? 7 A. They asked me what happened. Did I ever see 8 anything. And I told them what I heard. 9 Q. Okay. Did they ever advise you that they had 10 intercepted you on phone conversations? 11 A. No. 12 Q. Did they advise you that they had undercover 13 people that had intercepted you or talked to you or 14 aware of activities that you were involved in? 15 A. No. 16 Q. So all you know is that out of the blue, the 17 Davie police comes to you, correct? 18 A. Yes. They called me, yes. 19 Q. And you go down there? 20 A. (No verbal response.) 21 Q• All right. Here it is, Detective Yager says 22 to you: 23 "YAGER: We're responsible for an 24 investigation of a murder that occurred here in Davie. 25 This is your card, Mr. Titone? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128452 Page 19 1 "TITONE: Thank you, sir. Here you go. 2 "Involving a Mr. Michael Bilotti. And we know 3 from surveillance and investigation that is continually 4 ongoing that you've met with Mr. Bilotti on more than 5 one occasion. 6 "MR. KADOSH: Yes. 7 "YAGER: And the investigations were able to 8 ascertain some of your conversations, but not every bit 9 of it. And since I believe you have nothing to do with 10 this murder -- and by no means is Mr. Kadosh a subject 11 of any criminal investigation or nor do we have any -- 12 MR. WILLIAMS: By the Davie police department. 13 MR. HADDAD: Dohn, do you want to do it? 14 MR. WILLIAMS: No. No. 15 BY MR. HADDAD: 16 Q. "By the Davie Police Department, nor do we 17 have any information to believe he's involved in any 18 criminal activity, but we wanted to give you an 19 opportunity to discuss with us things that may have been 20 discussed by you -- with you, by Mr. Bilotti, 21 particularly concerning a couple of murders that may 22 have been mentioned." 23 Did they tell you intimate to you or in any 24 way advise you of how they knew what your conversations 25 were with Mr. Bilotti? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128453 Page 20 1 A. I don't remember. 2 Q. Did anyone -- at the time that you talked to 3 Bilotti about murder -- and we'll get to that in a 4 little bit, the only persons that those were discussed 5 with would have been you, what you said that Zedeck said 6 and what Ralph Feo overheard, correct? 7 A. (No verbal response.) 8 Q. Yes? 9 A. I think so. I don't remember exactly. 10 Q. Well, did you tell anyone so that they could 11 have gone running to the cops that Mr. Michael Kadosh 12 was talking about murders -- 13 A. Well, I told when the people called me from 14 the state office -- 15 Q. No. No. 16 A. -- from the police. 17 Q. No. No. I'm talking about when you and 18 Bilotti were having these conversations, like, when he 19 was supposedly going to whack your son-in-law and 20 everything, did you go tell the police? Did you tell 21 anybody? 22 A. I did not. 23 Q. So all of this would have to have been 24 something overheard, like the police said, for them to 25 know, correct? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128454 Page 21 A. What I said? 2 Q. Yeah. No. No. Before that. When they came 3 to you and said, we know from conversations that you had 4 with Bilotti about murders, it certainly wasn't 5 something you went and told the cops. 6 A. No. I didn't tell. 7 Q. You didn't tell your wife to go tell the cops? 8 A. No. 9 Q. You didn't tell your daughter to go tell the 10 cops? 11 A. No. 12 Q. You didn't tell Feo to go tell the cops? You 13 didn't tell anybody, right? 14 A. No. 15 Q. Okay. So it would have had to have come from 16 intercepted conversations, correct? 17 A. I don't know how, but -- 18 MR. ROSSMAN: If they actually knew anything. 19 MR. HADDAD: Well, that's what we're going to 20 find out at some point within the next day or two. 21 BY MR. HADDAD: 22 Q. So did you have phone conversations with 23 Mr. Bilotti where somebody might have discussed being 24 killed? 25 A. No, not a phone conversation. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128455 Page 22 Q. Not a phone conversation. 2 Okay. So you don't know whether or not 3 they're piecing together conversations that maybe 4 related to Bilotti or Zedeck, or other persons 5 conversing regarding this crime, correct? 6 A. I don't know. 7 Q. Okay. Now, since I don't want to keep you 8 here all day. 9 MR. ROSSMAN: Can I ask one question about 10 following-up on what you said? 11 MR. HADDAD: Go ahead. 12 MR. ROSSMAN: Did you ever tell Mr. Titone? 13 THE WITNESS: Yes. 14 BY MR. HADDAD: 15 Q. When? 16 A. When I went to the police. 17 Q. Yeah, you told him that day. 18 A. Yeah, I told him that. He says, you have to 19 tell the truth. I said, that's all I'm going to tell. 20 Q. Titone said that? 21 A. Yeah. 22 Q. Okay. So the only person that you have ever 23 said any of this to, other than when you gave this 24 statement, would have been to Joe Titone on that day 25 when the cops came to get you -- Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128456 Page 23 A. Yes. 2 Q. -- and told you, you had to be there? 3 A. Uh-huh. 4 Q. All right. Now, let's go from there. You 5 don't know when this statement was given unfortunately. 6 A. No, I don't. 7 MR. ROSSMAN: Excuse me a minute. It should 8 be in there. 9 BY MR. HADDAD: 10 Q. Okay. So in there it says that you were 70 11 years old. You're 74 now, when are you going to be 75? 12 A. In October. 13 Q. All right. So it could have been somewhere 14 four or four-and-a-half years ago, somewhere around 15 there, true? 16 A. Probably. 17 MR. ROSSMAN: I should be able to get you the 18 exact date if we don't have that. 19 MR. HADDAD: Yager didn't put a date. 20 MR. ROSSMAN: I was going to say, Yager should 21 have it in his report. 22 MR. HADDAD: It's not anywhere here. The 23 court reporter transcribed it for me in 2014. I 24 sent the tape over there, because I had a CD of 25 this. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128457 Page 24 MR. ROSSMAN: Before we leave today, I should 2 be able to get you that. 3 MR. HADDAD: Okay. 4 BY MR. HADDAD: 5 Q. So at any rate, you first met Bilotti and/or 6 Zedeck -- who did you meet first? 7 A. Zedeck. 8 Q. And you were doing business with Zedeck 9 with -- what is it, Trans America Bank? 10 A. TransCapital Bank. It was called Trans 11 Florida before. 12 Q. Okay. You had been doing business with them 13 for a period of years, correct? 14 A. Twenty. 15 Q. Three years prior? 16 A. Twenty years. 17 Q. Twenty years. So you knew the Zedeck 18 brothers? 19 A. Yeah. 20 Q. For 20 years? 21 A. Yeah. 22 Q. And you had done business with them for 20 23 years? 24 A. Yes. 25 Q. Okay. And during that period of time, I know Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128458 Page 25 1 you did hotels, you did different things. You had 2 construction loans? 3 A. Yes. 4 Q. All of that other stuff, we don't need to get 5 into that now. 6 And then at some point you meet Mike Bilotti. 7 A. Yes. 8 Q. Did you know Mike Bilotti before you had that 9 first business deal with him? 10 A. I saw him at the bank a few times when I went 11 to make a deposit, but I didn't know exactly who he was. 12 Q. Did he have an office at the bank? 13 A. I found out later he had an office with 14 Zedeck's office at the bank. 15 Q. Okay. 16 A. The same office as Zedeck's office. 17 Q. Right. Which Zedeck? 18 A. Leonard Zedeck. 19 Q. Leonard Zedeck. 20 A. Yeah. He had it on Oakland Park. His office 21 is the same address. 22 Q. Okay. Now, when you first -- you were sort of 23 a good customer of the bank. You're back and forth, and 24 construction goes up, goes down. One day you're rich, 25 one day you're poor. One day you can't make your Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128459 Page 26 payments, one day you sell a building for 10 million 2 bucks, correct? 3 A. Yes. 4 Q. All right. And so I take it they would float 5 you money now and then? 6 A. At the time, yes. 7 Q. Okay. And then, of course, some time around 8 2008 the banks started having problem with money and 9 regulations. 10 A. Yes. 11 Q. Because they started checking credit and doing 12 all that other stuff, correct? 13 A. Yes. 14 Q. All right. Approximately -- can you put a 15 year when you met Mike Bilotti? 16 A. I can't. I think 2008, 2009, maybe. 17 Q. You had seen him for how long of a period of 18 time before that? Years? 19 A. I had seen him a few times at the bank. 20 Q. Did he ever talk to you? 21 A. Yeah. He said, hello. But I didn't know who 22 he was. 23 Q. Okay. Did he threaten to whack you when you 24 said, hi? 25 A. No. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128460 Page 27 Q. Okay. So he said, hello. You would talk, you 2 would be back and forth, correct? 3 A. Yeah, once or twice before. 4 Q. Okay. And then there comes a point in time 5 where, from what I read in your statement, you needed 6 money from the bank. You needed a significant amount of 7 money and they said that Bilotti had to be involved, 8 correct? 9 A. No, that's not the case. 10 Q. Okay. 11 A. I had a commitment to the bank to do 12 construction for two million. 13 Q. Right. 14 A. They gave $600,000 and they stopped. 15 Q. And then the other million four they wouldn't 16 give you unless Bilotti was the one that signed, got the 17 money and paid everybody? 18 A. Right. Right. And he didn't pay anybody. 19 Q. I could say it completely correct if you want 20 me to, but I'm just trying to get the gist of it. 21 A. Yeah. 22 Q. If we have to go through every single part of 23 the details, we'll be here till 6:00 tonight. 24 A. No. 25 Q. I mean, it's business. I'm getting to the Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128461 main parts. 2 A. No problem. 3 Q. I mean, I could save the long stuff 4 you're on the witness stand. 5 A. All right. 6 Q. Okay. So what happened? How does it come 7 about that you agree with this proposition to have Mike 8 Bilotti take a million four that you have a commitment 9 for, and in essence, take over your corporation and 10 continue the construction? Why do you do that? 11 A. I had no choice, otherwise the bank would 12 foreclose on me. 13 Q. You were behind? 14 A. Yeah, I was behind and the bank said Bilotti 15 is going to front the loan, and it will be 50/50, but 16 the paper said 80/50 [sic], but it was 80 percent to him 17 and 20 percent to me. 18 Q. Yeah, we're not here on the civil case. I 19 don't care about that. 20 A. Well, that's what happened. 21 MR. ROSSMAN: I care. It took him two 22 seconds. We should get the right facts if you're 23 going to ask him on the stand. 24 MR. HADDAD: I didn't ask that facts. I just 25 asked how he did it. If I want that facts, I'll Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128462 Page 29 ask for it. 2 MR. ROSSMAN: You said you were going to ask 3 him on the stand. 4 MR. HADDAD: Sure. I'm going to ask him on 5 the stand. I don't need to go through it now. 6 BY MR. HADDAD: 7 Q. When they said that Bilotti was going to do 8 this, had you spent any time with Michael Bilotti before 9 that? 10 A. No. 11 Q. So you just saw this short fat guy walking 12 around -- 13 A. The bank had brought him and says, he's going 14 to get the loan in his name and give him half. 15 Q. Did you do any investigation of this person 16 that was becoming your partner? 17 A. I did not. 18 Q. Were you told anything about him by Mr. Zedeck 19 or his partner? 20 A. I had no choice, they told me to take him and 21 that's it. 22 Q. Yeah, I understand you had no choice. We'll 23 get to the no choices. 24 A. I didn't know. I found out later. 25 Q. No. No. Did they tell you anything then? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128463 A. No. Q• Did you know what kind of busines at the time -- A. I did not. Q. Okay. Did you know whether he had any knowledge of construction, hotels, business management? A. I did not. Q. Okay. And you signed a contract with him? A. Yeah. 10 Q. Okay. Is that the one that Zedeck said, if 11 you don't sign it, we're going to whack you? 12 A. Yes. 13 Q. Okay. And that was Zedeck who said that? 14 A. Yeah, it was -- Bill Himes, who is the 15 president of the bank -- 16 Q. Right. 17 A. -- and Zedeck. 18 Q. And they said to you, if you don't sign this 19 contract giving Bilotti -- letting Bilotti be this 20 manager of this money, who's going to whack you? 21 Bilotti? 22 A. Well, they didn't say Bilotti. They said that 23 they foreclose on me. I would lose everything. So I 24 said, let me bring my lawyer. They wouldn't let me 25 bring my lawyer. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128464 Page 31 1 Q. Yeah, but you said that you almost had a gun 2 put to your head and they said if you didn't sign this 3 loan, Bilotti was going to have you whacked. 4 A. No, he didn't say, was going to be whacked, he 5 said that they'd foreclose on me. And that Bill Himes 6 told me, who is the president of the bank, that Bilotti 7 will whack me. I said, well I don't want to be whacked. 8 Q. Bill Himes told you that, not Zedeck? 9 A. Yeah. Yeah. 10 Q. And that was -- 11 A. Bill Himes is the president of the bank. 12 Q. All right. 13 A. He says you better sign. So I signed it. 14 Q. Okay. But you had a lawyer? 15 A. No, I didn't have a lawyer. 16 Q. You just said they wouldn't let you bring your 17 lawyer. 18 A. They wouldn't let me bring the lawyer, right. 19 Q. They wouldn't let you bring your lawyer. 20 A. Right. 21 Q. Yeah, okay. 22 A. So I said, can I bring my lawyer, they said, 23 no. 24 Q. Who was your lawyer? 25 A. Ben Jacobi at the time. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128465 Page 32 Q. Okay. Now, you're there, you're going to lose 2 -- well, you still have a building, correct, they were 3 going to foreclose? You still had the construction 4 going on, correct? 5 A. No, it was stopped. 6 Q. It was stopped, all right. 7 Now, you signed this loan? 8 A. Right. 9 Q. Did you get to meet Bilotti then? 10 A. Yes. 11 Q. What was your relationship? 12 A. Well, it was partner. The bank told me, he 13 was good, so I took -- 14 Q. Well, did you sit and meet with him? 15 A. I talked to him many times, yes. 16 Q. All right. You used to go to that Turkish 17 restaurant Sultans? 18 A. Yes. 19 Q. And he used to come down at least once or 20 twice a week to the building site, correct? 21 A. No, he used to come to sign the checks. 22 Q. Yeah, every Friday he signed the checks, I 23 know that. I read all that. 24 But he'd come down once in a while during the 25 week to examine the site, didn't he? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128466 Page 33 A. Yeah. 2 Q. He took an active interest in it. 3 A. More or less. 4 Q. I mean, he just wasn't -- 5 A. He didn't know anything about construction. 6 Q. Okay. Do you know how many hotels he owned at 7 the time? 8 A. I don't know. 9 Q. Do you know how many restaurants and other 10 businesses he owned? 11 A. Restaurants, he did own. 12 Q. Okay. Do you know whether or not he owned the 13 Holiday Inn in Fort Pierce? What he owned in South 14 Beach? 15 A. No, I didn't know. 16 Q. Okay. So he comes down and every Friday he 17 signs the checks? 18 A. Right. 19 Q. And pays the bills? 20 A. Uh-huh. 21 Q. Correct? 22 A. Yes. 23 Q. Construction is going on again. Everything is 24 going according to plan, correct? 25 A. Uh-huh. Yes. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128467 Page 34 Q. Okay. Ralph Feo is there. Is he your 2 contractor? 3 A. Yes. 4 Q. And Feo is there, and he's there on Friday's 5 to get paid with 6 A. Yes. 7 Q. -- the moneys, correct? 8 A. Yes. 9 Q. Does the building get completed? 10 A. It was completed, yes. 11 Q. What year? 12 A. I believe 2011. 13 Q. That's after Bilotti was charged in this case, 14 correct? 15 A. I don't know when he was charged. 16 Q. Didn't you look it up to see when he got 17 arrested, you told us -- you told the cops? 18 A. Well, later on we Googled his name, and it 19 came all the stuff came up. 20 Q. Well, he got arrested in 2008. Were you 21 business partners with him in 2008? 22 A. Not that I know. 23 Q. And no one told you -- what year did you sign 24 the loans? 25 A. I don't remember, '09, '10. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128468 Page 35 Q. You sold -- 2 A. I sold property in '11. 3 Q. '11, so how many years did it take to complete 4 it? 5 A. Maybe a year and a half or so. 6 Q. Okay. So give it a year and a half, so that's 7 2009. In 2009 you didn't know Bilotti had been 8 arrested? 9 A. In 2009, I didn't know. 10 Q. Okay. In 2011, when you sold the building, 11 how much did you get? 12 A. I. got from 15 million, I got a million two. 13 Q. Okay. And who got the rest? 14 A. Bilotti. 15 Q. Bilotti got $14 million? 16 A. No, he got whatever the difference was. I 17 don't know exactly how much he got. 18 Q. Well, you said you sold it for $15 million or 19 did I not hear right? 20 A. Yes, we had to pay the mortgages and all -- 21 Q. How much was the mortgage? 22 A. I don't remember. The mortgage was -- 23 Q. $13 million? 24 A. No. No, not $13 million. The mortgage was 25 maybe $10 million, nine, I don't remember exactly the Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128469 Page 36 1 amount. 2 Q. How many partners were there in that besides 3 you and Bilotti? 4 A. That's the only one that I know of. 5 Q. How much was there to split between the 6 individuals? 7 A. I don't know. I didn't see the final. 8 Q. You didn't see the closing papers? You didn't 9 see anything? 10 A. They just gave me a check. He took 80 percent 11 and the 20 percent was mine. 12 Q. And that's your testimony? 13 A. Yes. 14 Q. Okay. You never saw the paperwork? 15 A. I don't remember whether I saw it or not. 16 Q. Did you sign the paperwork for the closing or 17 you don't remember that? 18 A. I'm sure I had to sign it, yes. 19 Q. Okay. And when you signed the paperwork -- 20 you've been a businessman for 40 years, did you read 21 anything that you were signing? 22 A. I did, but I don't remember the numbers. 23 Q. What did it say? 24 You didn't look at the numbers? 25 A. I said, I don't remember. Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128470 Page 37 Q. What do you think it said, if you had to take 2 a wild guess? 3 A. Say what? 4 Q. What did the numbers show? The closing 5 documents are available. 6 A. Well, you could get it. 7 Q. I'm trying to test your memory right now, sir. 8 A. well, I don't remember that. 9 Q. You've said a lot of things that you seem to 10 remember clearly, so I'm just trying to see if something 11 as important as millions of dollars you would remember, 12 that's all. 13 A. All I remember is I got a check for a million 14 two, that was my share. 15 Q. A million two, okay. 16 And so from being in foreclosure -- 17 A. I was never in foreclosure. 18 Q. From being close to default 19 A. Yeah. 20 Q. Whoa. Whoa. Let me finish my question. 21 -- and being in a situation where you were in 22 default, in essence, because the bank wouldn't give you 23 the million four that you needed to complete your 24 construction loan, you walked out with a million two 25 when it was over? Bailey & Associates Reporting, Inc. 954-358-9090 EFTA01128471 Page 38 A. Yes. 2 Q. Okay. I just want to make sure. 3 Now, did you have any other business dealings 4 with Bilotti other than that building? 5 A. No. 6 Q. So that's the whole entirety of your -- 7 A. Of the Peter Miller Hotel. 8 Q. I'm
To: Cecile de Jong Cc: 1 :1aphne Wallace From: Sent: Tue 2/24/2015 6:00:59 PM Subject: Re: JE's Schedule - February 25th - I just received word that the deposition for tomorrow is cancelled...so it is fine for JE to have this below meeting at 2pm!! On Feb 24, 2015, at 12:05 PM, Cecile de Jongh wrote: February 25th - STC 2 PM - Meeting with Carlton Do Miller (UEIS), and Dale Gregory (VIPA) at STC POC Carlton Dow Shaun Miller- United Electronic Industries Services, LLC (UEIS), founded in 1990, is a leader in the PC / Ethernet data acquisition and control, Data Logger / Recorder and Programmable Automation Controller (PAC) and Modbus TCP markets. UEIS sells its technology products to the following industrial sectors: automotive, aerospace, petroleum/refining, simulation, semiconductor manufacturing, medical, HVAC, power generation and more. UEIS is headquartered in Walpole, Massachusetts and also has its research & development on St. Thomas. Key Customers: Boeing, Raytheon, Lockheed Martin, Rolls Royce, General Electric, NASA, Sikorsky, Bosch and many other multinational technology firms Business Location: St. Thomas Industrial Park St. Thomas, U.S. Virgin Islands in January 2012 with 10 employees as of May 2012 Business Activity: UEIS has built a state-of-the-art manufacturing, assembly, test and shipping facility to supply its worldwide customer base from the St. Thomas. With warm regards, Cecile EFTA_R1_00670163 EFTA02083688
IN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA FILE NO. 502008CP003626XXXXMB Plaintiff, v. JEFFREY EPSTEIN, Defendant. CROSS NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that on February 11, 2010 at 9:30 AM at Prose Court Reporting Agency, Inc. One Clearlake Centre, 250 South Australian Avenue, Suite 1500, West Palm Beach, FL 33401, the undersigned attorney will take the deposition of: upon oral examination, before, Prose Court Reporting, Notary Public, or any other Notary Public or Officer duly authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The deposition is being taken for the purpose of discovery, for use at trial, or both of the foregoing, or for such other purposes as are permitted under the applicable and governing rules. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail and email on Janua , 2009 to: D. Critton, Jr., Esq., Burman, Critton, 1 EFTA00725914 et al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401; Jay Howell, Esq., Jay Howell & Assoc., 644 Cesery Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 (954)524-2822 fax By: BRADLEY J. EDWARDS Florida Bar No.: 542075 2 EFTA00725915
IN THE CIRCUIT COURT FOR THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA FILE NO. 502008CP003626XXXXMB Plaintiff, v. JEFFREY EPSTEIN, Defendant. ELSINILEall i VIDE DE rION OF PLEASE TAKE NOTICE that plaintievill take the video deposition by oral examination, of the persons named below, at the time, on the date, at the hour of the place indicated: NAME DATE AND PLACE OF TAKING DEPOSITON TIME June 15, 2010 @ Intern. ent Office 10:00AM upon oral examination before Videographer and a Notary Public, or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The depositions are being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the Rules of Court. 1 EFTA00612134 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail and email on May la- , 2010 to: Robert D. Critton, Jr., Esq., Burman, Critton, et al., ay Howell, Esq., Jay Howell & Assoc., and Jack Alan Goldberger, Esq., Farmer, Jaffe, Weissing, By: BRADLEY J. EDWARDS Florida Bar No.: 542075 2 EFTA00612135
IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. MOTION FOR PROTECTIVE ORDER AS TO THE DEPOSITION OF Third-Party Witness, by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Rule 1.280(c), Florida Rules of Civil Procedure, moves for a Protective Order to reschedule her deposition currently set for Monday, March 1, 2010 and states: 1. On February 3, 2010, counsel for Plaintiff, M., filed a Notice of Taking the Deposition of Third-Party Witness, 2. A Motion for Protective Order has been filed in Federal Court with respect to the same issue See Attached Exhibit A For the reasons set forth in the attached Motion, Third-Party Witness, , adopts same. 3. Undersigned counsel has agreed to provide dates to reschedule Ms. deposition See Attached Exhibit B 4. To avoid duplication, the same Motion for Protective Order is applicable in v. Jeffrey, Case No: 502008CA028058XXXXMB and M. v. Jeffrey Epstein, Case No: 502008CA037319XXXMB. WHEREFORE, Third-Party Witness, respectfully requests the EFTA00728112 Court enter a protective order allowing her deposition to be rescheduled from March 1, 2010, to another date to be agreed upon by all interested parties. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 13th day of October, 2009: Edwards, Esq. D. Critton, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Burman Critton Luttier & Coleman, LLP Lehrman, PL 303 Banyan Blvd. 425 N. Andrews Avenue Suite 400 Suite 2 West Palm Beach, FL 33401-5012 Fort Lauderdale, FL 33301 Fax: 561-842-2820 954-524-2820 Phone Counselfor Defendant Jeffrey Epstein 954-524-2822 Fax Counselfor Plaintiff.& EW Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. Jay Howell, Esq. 2925 PGA Blvd., Suite 200 Jay Howell & Associates, P.A. Palm Beach Gardens, FL 33410 644 Cesery Boulevard Fax: 561 697 2383 Suite 250 Counselfor Plaintiff. Jacksonville, FL 32211 904-680-1234 Phone 904-680-1238 Fax Co-counselfor Plaintiff ATTERBURY GOLDBERGER & WEISS, PA 250 Australian Avenue South Suite #1400 West Palm Beach, FL 33401 (561) 659-8300 By: JACK A. GOLDBERGER, ESQ. Florida Bar No: 262013 2 EFTA00728113
From: Sent: Thursday, October 18, 2018 3:48 AM To: jeffrey E. Subject: I was asked 10 years ago many times to write deposition against me EFTA_R1_01820850 EFTA02618006
To: Jeffrey Epsteinijeevacationggmailcomj From: Lesley Groff Sent Wed 4/28/2010 7:31:19 PM Subject: Dr. Karroum depo Dr. Karroum (therapist) is scheduled for a deposition tomorrow at 2:00 at 10111 W. Forest Hill Blvd., #369, Wellington, FL. Plaintiff is Doe #3 (Lopez) EFTA_R1_01493081 EFTA02424928
To: Jeffrey Epstein[jeevacationegmail.com] From: Sent Thur 4/16/2015 4:11:41 PM Subject: Sitrick DepotTentative Date for Elysium Trustees Meeting both May 5th FYI-you are scheduled for the Sitrick deposition in PB on May 5th at 10am in Jack's office...there is a tentative date for the Elysium Trustees of May 5th at 2:30 at the Apollo office... Do you need to be a part of the Elsyium Trustees meeting? (below is email from Ava at Elysium) Good afternoon Richard, Barry and John, The tentative date for the Trustees Meeting will be Tuesday, May S'h at 2:30 pm. If this date is acceptable for everyone to attend, I will reserve a conference room at Apollo and formally send out an invite. Thank you for your time. Best regards, Ava AVA LAMBERT OFFICE ADMINISTRATOR EI.YSIUM MANAGEMENT LLC 445 PARK AVENUE, Sum 1401 NwY RK NY 10022 EFTA_R1_00664363 EFTA02081228
Case 9:08-cv-80119-KAM Document 66-3 Entered on FLSD Docket 03/26/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, 11+ 1 1. JEFFREY EPSTEIN, DOCKET Defendant. NOTICE OF TAKING DEPOSITION VIA VIDEO PLEASE TAKE NOTICE that the undersigned attorney will take the deposition via video of: DEPONENT DATE & TIME LOCATION OF DEPOSITION Jane Doe #3 Tuesday, U.S. Legal Support do Stuart Mermelstein, Esq. April 14, 2008 444 West Railroad Avenue 18205 Biscayne Boulevard 9:00 a.m. Suite 300 Suite 2218 West Palm Beach, FL 33401 Miami, FL 33160 Phone: 561 835-0220 upon oral examination, before U.S. Legal Support, a Notary Public, or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for s ch other purposes as are permitted under the applicable Statutes of Rules of Court. Robert D Critton, Jr. Attome or Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was served this oiwn all counsel of record identified on the following Service by fax an U.S. Mail, this /kr—day of March 2009: Stuart S. Mermelstein, Esq. Jack Alan Goldberger Adam D. Horowitz, Esq. Atterbury Goldberger & Weiss, P.A. EXHIBIT "B" EFTA00221689 e Case 9:08-cv-80119-KAM Document 66-3 Entered on FLSD Docket 03/26/2009 Page 2 of 2 Jane Doe No. 21. Epstein Page 2 Mermelstein & Horowitz, P.A. 250 Australian Avenue South 18205 Biscayne Boulevard Suite 1400 Suite 2218 West Palm Beach, FL 33401-5012 Miami, FL 33160 561-659-8300 305-931-2200 Fax: 561-835-8691 Fax: 305-931-0877 jacesoabellsouth.net ssmasexabuseattorney.com Co-Counsel for Defendant Jeffrey Epstein ahorowitzasexabuseattorney.com Counsel for Plaintiff Jane Doe #2 Respectfully subs itted, By: ROBERT D TTON, JR., ESQ. Florida Bar o. 224162 rent bele' w.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikaelclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Co-Counsel for Defendant Jeffrey Epstein) Courtesy Copy: U.S. Legal EFTA00221690
IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA B.B., CASE NO. 502008CA0373193OOOCMB AB Plaintiff, v. and Defendants NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces tecum (See attached Exhibit "A") of: DEPONENT DATE & TIME LOCATION OF DEPOSITION Det. Joseph Recarey February 25, 2010 Prose Court Reporting do Joanne M. O'Conner, Esq. at 9:30 AM One Clearlake Centre Jones, Foster, Johnson 250 Australian Avenue South & Stubbs, P.A. West Palm Beach, FL 33401 505 S. Flagler Drive, #1100 West Palm Beach, FL 33401 upon oral examination, before Prose Court Reporting, a Notary Public, or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes of Rules of Court. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S Mail to the following addressees on this 3rd day of February, 2010: Theodore J Leopold, Esq. Jack Alan Goldberger, Esq. Spencer T. Kuvin, Esq. Atterbury Goldberger & Weiss, P.A. Leopold-Kuvin, P.A. 250 Australian Avenue South 2925 PGA Blvd., Suite 200 Suite 1400 EFTA01074860 B.B v. Epstein, et al Page 2 i Palm Beaciirdens, FL 33410 West FL 33401-5012 Fax:im Fax: Counsel for Plaintiff Co-Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 N. Flagler Drive, Suite 400 h, FL 33401 Robe . Critton, Jr. Florida Bar #224162 Mi mel J. Pike Florida Bar #617296 (Colonel for Defendant Jeffrey Epstein) EFTA01074861 EXHIBIT "A" red by you or any 1 Any and all written reports, notes, memoranda or other papers autho in hard-copy or electronic form, other member of the Palm Beach Police Department, whether in including but not limited to that relate to any law enforcement investigation of Jeffrey Epste es against Mr. Epstein This the investigation that resulted in the filing of State criminal charg members of the Palm Beach request includes any written communications between you and any t Agency, any member of the Police Department, any member of any Federal Law Enforcemen the State Attorney, any Unites States Attorney's Office, any member of the Office of sses and/or any lawyers or representatives of the media, any civil parties, any civilian witne representatives of any parents of any civilian witnesses. of the following 2. Any and all electronic communications (EMAIL) between yo any in including but not limited to the relating to any law enforcement investigation of Jeffrey Epste s against him: (A) any member of investigation that resulted in the filing of State criminal charge Federal Law Enforcement Agency, the Palm Beach Police Department, (13) any member of any member of the Office of the (C) any membe f the Untied States Attorney's Office, (D) any radio media outlet, (F) any attorney State Attorney g) any member of any print, television, or or may potentially file a civil representing any civilian witness or civil party who has filed complaint against Mr Epstein. any communications between you 3 Any and all notes, memoranda or reports reflecting d to any request for exculpatory and counsel on behalf of Mr. Epstein, including but not limite evidence. attempts by you to initiate or 4. Any and all notes, memoranda or reports reflecting any igation or State prosecution encourage a federal review of any facet/aspect of the Epstein invest of Epstein laints made to the Palm 5 Any and all notes, memoranda or reports reflecting any comp for any person or parent claiming to Beach Police Department from any person, parent, or lawyer other private citizen of Palm have been a victim of any conduct of Mr Epstein or from any y 1, 2000 — October 22, 2009. Beach County relating to any conduct of Epstein from Januar ion between you or 6. Any and all notes, memoranda, or reports reflecting any communicat with "A H." in relation to her and any other member of the Palm Beach Police Department Grand Jury, before a State being subpoenaed to testify before or her requested attendance would testify to and/or any including but not limited to any discussions regarding what she with prior to any testimony. preparation that any law enforcement officer provided her communication between you or 7. Any and all notes, memoranda, or reports reflecting any "A H."* or referencing "A.H "* in any other member of the Palm Beach Police Department with requested attendance before a State relation to her being subpoenaed to testify before or her l sought to discourage her or Grand Jury where you or any Palm Beach police officer or officia any Grand Jury proceeding influence her not to testify or to testify in a certain manner at involving Mr. Epstein. EFTA01074862 electronic or otherwise, 8. Any and all agreements, memoranda, and/or notes of any kind, Department, any member of the Office between you and any member of the Palm Beach Police Attorney's Office relating to any of the State Attorney, and/or any member of the United States any time. criminal charges, formal or otherwise, regarding "A II " at communications between you 9. Any and all notes, memoranda, or reports of meetings or "• and "S.G "*, her parents, or any lawyers who represent "S.G_ you, and all requests for 10. Any and all records of expenditures made or incurred by Epstein. expenditures relating to the criminal investigation of Mr. s, memoranda or notes, and 11. Any and all logs, pictures, videos, digital information, report of and/or maintenance of any video any record of expenditure, which relate to the institution during the following time periods: surveillance of Mr. Epstein, his residence, or his visitors a January 1, 2004-December 31, 2004 b. January 1, 2005-December 31, 2005 c January 1, 2006-December 31, 2006 d. January 1, 2007-December 31, 2007 January 1, 2008-December 31, 2008 f. January 1, 2009-today's date. expenditures or any other 12. Any and all reports, logs, pictures, videos, notes, records of in, his residence, his visitors, or memoranda relating to any physical surveillance of Mr. Epste or co-conspirator other than the any individual who was believed to be a potential witnesses request number 11 information relating to video surveillance that is requested in notes, and reports of any 13. Any and all reports (including forensic reports), memoranda, nce in October 2005 or on any examination of any computer seized fiom Mr. Epstein's reside other occasion. or burglary 14. Any and all reports, memoranda, or notes reflecting a criminal theft prior to October 2005. investigation of Mr. Epstein or his residence on any occasion cell phone, used by you 15. All cell phone records, both official cell phone and personal between during the following time periods: a. January 1, 2004-December 31, 2004 b. January 1, 2005-December 31, 2005 c January 1, 2006-December 31, 2006 d. January I, 2007-December 31, 2007 January 1, 2008-December 31, 2008 f. January 1, 2009-today's date. periods between October 1, 16.. All calendars or diaries, electronic or hard-copy, kept for the activities, meeting, etc. 2004 up through and including today, reflecting your schedules, EFTA01074863 17. Any and all reports, memoranda, and notes of any communication between Los and any member of the Office of the State Attorney relating to the criminal investigation and subsequent prosecution of Mr. Epstein from October 1, 2004 up through and including today. 18. All policies and procedures of the Palm Beach Police Department setting forth the procedures for police officers, including the Chief, any detective and officers when commenting to any media outlets, including but not liming to the local news, the national media, print outlets, and any web-based media format. 19. All personal notes contained either on your personal computer, work computer, and those that are handwritten containing any witnesses that you, or any other member of the Palm Beach Police Department interviewed or attempted to interview with regard to the Epstein investigation from January 1, 2004, up thorough and including today. 20. Any and all audio tapes of any witnesses that You or any member of the Palm Beach Police Department obtained statements or interviews from, either sworn or informal, with regard to the Epstein investigation 21. Any and all audio tapes, notes (hand-written or typed), memoranda, reports, messages, and/or any communications obtained or generated by you or any member of the Palm Beach Police Department, either sworn or informal, that relate to Jane Doe fie*, who is the Plaintiff in a Federal Civil Case No. 08-80380 filed against Jeffrey Epstein. * The initials Ail. and S.R. refer to the individuals identified in the Palm Beach County Probable Cause Affidavit ns it relates to the Jeffrey Epstein investigation. Should ou re uire the complete name of the individuals, please contact Jessica Cadwell at ** Should you need the full identity of Jane Doe #4, please contact Jessica Cadwell at 561- *842-2820. EFTA01074864
From: To: Cc: Subject: [EXTERNAL EMAIL] Date: Tue, 11 Aug 2020 16:51:05 +0000 Importance: Normal Attachment Transcript_Vol_l_(6-24-16).pdf Transcript_Vol_2_(6-24- 16).pdf As we discussed, I'm attaching the deposition transcripts. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00152667
Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 11-61338-CIV-COHN In Re: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. ORDER DENYING TRUSTEE'S MOTION TO CONTINUE DEPOSITION ORDER DEFERRING RULING ON MOTION TO BIFURCATE PROCEEDING ORDER DIRECTING RESPONSE BY TRUSTEE TO CROSS-MOTIONS ORDER DENYING ALL REQUESTS FOR RELIEF NOT RELATED SPECIFICALLY TO THE DEPOSITION OF SCOTT ROTHSTEIN THIS CAUSE is before the Court upon the Trustee's Expedited Motion to Amend Writ of Habeas Corpus Ad Testificandum [DE 53], Gilbraltar Private Bank & Trust Company's ("Gilbraltar") Response [DE 59] and Cross-Motion to Compel the Government to Produce Scott Rothstein Under Conditions that are Fair [DE 83], Levinson & Company's Response [DE 60], SFS Capital Funding and Frank Preve's Response [DE 61], Ed Morse, Carol Morse and Morse Operations, Inc.'s Response and Supplemental Response [DE's 57 and 62], Razorback Victims' Response [DE 63], Counsel for Scott Rothstein's Response [DE 64], TD Bank, N.A.'s Response [DE 65] and Cross-Motion for Remedial Relief Related to Unauthorized Disclosure of Information [DE 79], Federal Insurance Company's Response [DE 66], Government's Response [DE 67] and Ex Parte Memorandum [DE 69], Emess Capital, LLC's Joinder in Trustee's Motion [DE 70], Brian Levy's Response [DE 71], SPD Group, Inc.'s Response [DE 72], Platinum Partners Value Arbitrage Fund LP ("Platinum")'s Response [DE 74] and Cross-Motion for Discovery and Sanctions regarding RRA Trustee's Violation of Court Order [DE 81], the Regent Defendants' Response [DE 76], and the EFTA01114325 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 2 of 8 Amended Response of the RLI Insurance Company, et al ("Insurance Companies") [DE 78]. The Court has carefully considered all of the filings in this matter, and is otherwise fully advised in the premises.' I. BACKGROUND Scott Rothstein ("Rothstein"), the central figure in a criminal action brought by the United States of America regarding fraudulent activities undertaken by Rothstein while he controlled the now bankrupt law firm of Rothstein, Rosenfeldt & Adler, P.A. ("RRA"), is set to be deposed in the RRA bankruptcy action and various civil actions pending in federal and state courts. After lengthy negotiations among the parties involved at the time, and after rulings by the Bankruptcy Court and this Court, the Court ordered that the examination/deposition of Scott Rothstein shall take place commencing December 12, 2011, under the protocol described in United States Bankruptcy Judge Raymond Ray's proposed Writ, except as modified by this Court (e.g. the deposition shall not be videotaped based upon matters of security).2 On November 10, 2011, the Trustee moved to Amend the Writ because the Trustee's filing of 46 additional adversary actions has created a group of affected parties who could not meet the security protocol deadlines to participate in Rothstein's December deposition. This Court directed all parties, including the Government, to file expedited responses to the Trustee's motion. Many of those parties have filed such ' Given the December 12, 2011 deposition date and the travel arrangements required, the Court declines to wait until reply memoranda are filed. = For the full background of this action, please see the Court's Orders dated July 1, 2011 [DE 32] and September 6, 2011 [DE 50]. The Writ itself is filed at docket entry 52. 2 EFTA01114326 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 3 of 8 responses. TD Bank and Platinum have also filed cross-motions for remedial relief related to the allegedly unauthorized disclosure of information by Trustee's counsel and Trustee. II. DISCUSSION The present filings require the Court to once again balance the irreconcilable rights and duties of various parties: the Government's duty to prosecute alleged criminal acts, the United States Marshal's Service obligation to protect witnesses, the Bankruptcy Trustee's duty to marshal assets of a defunct law firm and distribute funds to RRA's creditors, civil plaintiff victims of Rothstein's fraud schemes, and civil defendants faced with multi-million dollars of liability.' In its prior orders, the Court has discussed the legal balancing tests that apply to these types of situations. See In Re Rothstein Rosenfeldt Adler, P.A., 2011 WL 2620187, *2-3 (S.D. Fla. July 1, 2011); In Re Rothstein Rosenfeldt Adler, P.A., 2011 WL 3903567 (S.D. Fla. Sept. 6, 2011). A. Deposition To summarize the present dispute, the Trustee moved to amend the deposition protocol by either continuing the deposition or bifurcating the deposition. A bifurcation would allow a second deposition for those parties who could not meet the security protocol deadlines for counsel to obtain the appropriate clearance to participate in the December deposition of Scott Rothstein. These parties, generally defendants in adversary proceedings brought by the Trustee, could not have had sufficient notice to submit the information necessary to participate. Many of these parties join in one or Not all civil defendants are in the same position, as some were only recently served with adversary actions, while others face trial in the next few months. 3 EFTA01114327 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 4 of 8 both parts of the Trustee's requested relief of either a continuance of the December deposition or a bifurcation to allow a second deposition in 2012. The Government does not oppose a brief continuance based upon the Marshal's Service concerns regarding accommodation of the number of counsel participating in the December deposition amidst the crush of December family visits in federal prisons across the country. The Government opposes bifurcation because it only agreed to the protocol adopted by Judge Ray because of its belief that only one deposition would occur. The Government cites the burden on the understaffed Marshal's Service in having to accommodate a second deposition. Finally, the Government states that accommodating state court litigants is not required by this Court. The parties objecting most strenuously to any continuance of the deposition are those parties facing an early 2012 trial date in state court, the Razorback Victims and Gilbraltar. These parties argue that in setting its trial schedule, the state court relied upon this Court's emphatic order that the Rothstein deposition would be held in December and not delayed further. A delay of the deposition, even until January, would disrupt the schedule in that case. Gilbraltar also filed a cross motion contending that the United States Marshal's security procedures requiring short notice of the location of the deposition and the inability for counsel to bring a computer are unreasonable. Counsel foresees that it will be left to question Scott Rothstein just days before Christmas without the ability to timely return home. This Court finds that under the circumstances and given the statutory duties of the Marshal's Service with regard to witness protection, its security procedures are not unreasonable. 4 EFTA01114328 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 5 of 8 TD Bank, a party presently a defendant in a civil action in trial before another judge of this Court, joins in the continuance request because "all four of the attorneys for whom the requisite security information was provided . . . are presently engaged in trial," and it would be unfair and prejudicial to require that "counsel" turn immediately to the preparation for, appearance at and active participation in the Rothstein deposition. This argument is insufficient to support a continuance, as only one attorney is required to appear and participate in the deposition that has been scheduled five months in advance. The Court doubts that all four attorneys are required to appear every day in trial. With four experienced counsel, TD Bank will remain well represented in both the trial and the deposition on the present schedule. Counsel for Scott Rothstein responded to the Trustee's Motion by confirming that he is presently in a criminal trial in federal court in Boston, Massachusetts, in a case that he expects to go to the jury this week. However, because the presiding judge in that action is Chair of the United States Sentencing Commission, if not completed, his trial may resume on December 12, 2011, the date the deposition is scheduled to begin. Scott Rothstein opposes the motion for bifurcation. Upon weighing these competing arguments, the Court notes that significant resources have already been invested in having the deposition go forward on December 12, following this Court's July Order that the Court would not continue the deposition later than December. Second, the Government's arguments relating to the burden on the Bureau of Prisons and the Marshal's Service in having a December deposition could have been anticipated earlier. Third, a brief delay in the deposition that would accommodate the Government at the expense of certain parties would not 5 EFTA01114329 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 6 of 8 afford any relief to many more parties sued by the Trustee whose cases are new and may not be ready for Rothstein's deposition if held in January. Thus, the request to continue the deposition is denied. Turning next to the alternative relief of "bifurcating" the deposition to afford the additional parties a chance to participate in a deposition of Scott Rothstein, the Court need not decide this issue at this time. Any party who demonstrates a need to participate in a deposition of Scott Rothstein who is unable to participate in the December session because of the security restrictions imposed by the Marshal's Service, shall be afforded an opportunity to make a separate application for another deposition in early spring of 2012. Simply being sued by the Trustee in an adversary action is not by itself sufficient cause. Those parties who believe that they have sufficient cause to participate in a second deposition of Scott Rothstein shall coordinate their requests with the Trustee, who shall file a motion for such relief by January 18, 2012. Finally, to the extent that a party has made requests for relief beyond direct participation in a deposition of Scott Rothstein, such as the Federal Insurance Company, those requests are denied, without prejudice, as being outside the scope of this action, which is limited to the issuance of a writ of habeas corpus ad testificandum. B. Cross-Motions Both TD Bank and Platinum have filed cross motions for relief from alleged violations of this Court's Order allowing the Trustee special access to Scott Rothstein under assurances from the Trustee's counsel that he will not share the information gleaned from Rothstein with the plaintiffs in the civil cases. In re RRA, 2011 WL 6 EFTA01114330 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 7 of 8 2620187, *4. TD Bank alleges that the Trustee's counsel shared information with the Coquina plaintiffs in the action presently before Judge Cooke — information that purportedly formed the good faith basis for a line of questioning of a key witness in that case. See Exhibit C to Gilbratar's Response [DE 59-3]. TD Bank argues that the reason given by Trustee's counsel, the joint interest doctrine, cannot trump the direct conditions set by this Court for the Trustee's special access. TD Bank seeks various forms of remedial relief, listed at pages 11 and 12 of its Response and Cross Motion [DE 65]. In its cross-motion, Platinum asserts that the Trustee himself violated this Court's Order in a deposition in one of the bankruptcy adversary proceedings by testifying about what Rothstein told him about Frank Preve. Platinum seeks this Court to order that the Trustee and his counsel submit to discovery regarding any disclosures made to civil plaintiffs and set a date to determine appropriate sanctions. This Court takes seriously these allegations regarding possible violations of its order setting conditions upon the Trustee's special access to Scott Rothstein. Therefore, although such a response is likely forthcoming, the Court will set a date certain for the Trustee and his counsel to respond to the cross-motions. III. CONCLUSION Accordingly, it is hereby ORDERED AND ADJUDGED as follows: 1. The Trustee's Motion to Amend Writ of Habeas Corpus Ad Testificandum [DE 53] is hereby DENIED as to the request for a continuance; 2. A ruling on the alternative relief of bifurcation is hereby DEFERRED; 7 EFTA01114331 Case 0:11-cv-61338-JIC Document 85 Entered on FLSD Docket 11/28/2011 Page 8 of 8 3. Those parties who believe that they have sufficient cause to participate in a second deposition of Scott Rothstein shall meet and confer with the Trustee, who shall submit a motion for a second deposition by January 18, 2012, with prior consultation as to scheduling and security protocols with the Government and counsel for Scott Rothstein; 4. Gilbraltar Private Bank & Trust Company's Cross-Motion to Compel the Government to Produce Scott Rothstein Under Conditions that are Fair [DE 83] is hereby DENIED; 5. The Trustee and Trustee's counsel shall respond to TD Bank, N.A.'s Cross- Motion for Remedial Relief Related to Unauthorized Disclosure of Information [DE 79] and Platinum Partners Value Arbitrage Fund LP's Cross-Motion for Discovery and Sanctions regarding RRA Trustee's Violation of Court Order [DE 81] by December 9, 2011; 6. Any requests for relief that pertain to discovery in other cases are denied, without prejudice, as being outside the scope of this action, which is limited to the issuance of a writ of habeas corpus ad testificandum. DONE AND ORDERED in Chambers at Fort Lauderdale, Broward County, Florida, on this 28th day of November, 2011. ES I. COHN d States District Judge cc: copies to counsel of record on CM/ECF (Trustee's counsel shall forward this Order to any party not receiving notice via CM/ECF 8 EFTA01114332
To: JeeyacationUeeyacationegmaitcom]
From: story cowles
Sent Mon 4/5/2010 8:05:08 PM
Subject: Re: Weekly meeting
The weekly meeting legal meeting is tentatively set for Monday (12th) at 4:30pm. I say
tentatively because things may change this week regarding deposition scheduling. Jessica is
trying to get service on Melissa Kapusta (Rivera's friend) and Justin Vanover (Rivera's cx). Both
depos would be scheduled for next Monday (one in Gainsville and one in Tampa) and Jessica is
trying to figure out who would attend and if they would attend via phone. i will monitor and
keep you posted.
Story
--- On Mon, 4/5/10, Jeevacation leevacation@gmaiLcom> wrote:
From: Jeevacation
From: Darren Indyke MIS> To: Lesley Groff • > Subject: Re: Jeffrey Date: Thu, 15 Oct 2015 12:21:15 +0000 I actually will be their by 9. I am dialing in to a deposition that he wants to be able to listen to from time to time. DARREN K. INDYKE DARREN K. INDYKE PLLC New York, a N w Y rk 10022 Telephone: Telecopier: Mobile: email: The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - 2015 Darren K. Indyke, PLLC — All rights reserved. On Oct 15, 2015, at 7:52 AM, Lesley Groff • • wrote: Jeffrey has a totally packed schedule today. Did either of you need to try and see him? Sent from my iPhone EFTA00337901
Physical 1A/1C Cover Sheet for Serial Export Created From: 72-MM-113327 Serial 1 Package: 1A11 Stored FILE Location: Summary: (U//FOUO) Items migrated on 2010-02-01 Acquired By: Acquired On: 2010-02-01 Acquired (U) From: Attachment: (U//FOUO) FOUR (4) DVDS OF DEPOSITION OF ALFREDO RODRIGUEZ AUG 2009 EFTA00108623
AUG-05-09 09:54 FR0WLE0P0LDKUVIN, P.A. 1-361 P.001/001 F-984 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No: 502008CA0373193OOOCMB AB Plaintiff, VS. JEFFREY EPSTEIN Defendant. ED VIDEOTAPED DEPOSITION PLAINTIFF'S NOTICE OF TAKING CONTINU WILL TAKE THE DEPOSITION OF: PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY DATE AND TIME: LOCATION: NAME; August 7, 2009 Kress Court Reporting Alfredo Rodriguez 1:00 PM North Miami, FL 33179 by law to take depositions in upon an oral examination before a Notary Public or officer authorized ue from day to day until completed. The the State of Florida. The oral examination will contin at trial or are being taken for such depositions are being taken for purposes of discovery, for use other purposes as are permitted under the Rules of the Court. ' Notice was faxed and mailed I HEREBY CERTIFY that a true and correct copy this 41 day of August, 2009 to: Jack A. Goldberger, . West Palm Beach, FL 334101; Bruce E. Reinh art, Esq., Pike Beach, FL 33401; Robert D. Critton, Jr., Michael J. West Palm Beach, FL 33401. LEOPOLI/-KU YIN, P.A. MM chGT lens, Palm MM MM . FL 3341 By: S N UVINa_ESQ. . K_ Florid a Bar No: EMI EFTA00599384
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006CF009454AXX STATE OF FLORIDA SUBPOENA FOR DEPOSITION vs. JEFFREY EPSTEIN, Defendant. TO: a minor do Theodore J. Lepold, Esquire 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 YOU ARE COMMANDED to appear before a person authorized by law to take depositions on the 4th floor (Rooms 4.2004-4.2010), of the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on February 20, 2008 beginning at 9:30 a.m. for the taking of your deposition in this action. 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. WITNESS my hand and seal of said Court on this 5" day of February, 2008. J A. Gf berger, ESQ. or the Court 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 09112/2019 Page Agency to Agency Requet 19-411 CONFIDENTIAL SDNY_GM_00330059 EFTA_00202785 EFTA02728707 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 2006CF009454AXX STATE OF FLORIDA vs. NOTICE OF DEPOSITION JEFFREY EPSTEIN, Defendant. TO: Lanna Belohlavek, Esquire Office of the State Attorney 401 N. Dixie Hvg West Palm Beach, Florida 33401 on PLEASE TAKE NOTICE that pursuant to the Florida Rules of Criminal Procedure that s February 20, 2008 beginning at the hour of 9:30 A.M., at the Palm Beach County Courthouse 4th Floor, 205 North Dixie Highway West Palm Beach, Florida 33401: before Consor & Associates who is authorized by law to take depositions in the State of Florida, the Plaintiffs will, upon oral examination, take the deposition of the following named via telephone, to wit: 9:30 A.M. Such oral examination v,ill continue from day to day until completed. You are hereby notified to phone in and take part in said examination as you may be advised, and as shall be fit and proper. This deposition is being taken for the purposes of discovery, for use as primary evidence or for such other purposes as are pemiitted under the applicable Statutes or Rules of Court. I HEREBY CERTIFY that a copy of the foregoing Notice of Taking Deposition has been furnished to the above named addressee and Thedore J. Leopold, Esquire, 2925 PGA Boulevard, Suite 200, Palm Beach Gardens, Florida 33410 by via fax & mail this 56 day of February, 2008. ATTERBURY, GO DBERGER, & WEISS, P.A. 250 Australian A nue South, Suite 1400 'de 33401 JA K A. GOLDBERGER, ESQUIRE F ida Bar No. 262013 09/1212019 P 9 Agency to Agency Requet: 19-411 CONFIa ENTIAL SIDNY_GM_00330060 EFTA_00202786 EFTA02728708
To: Jeffrey E. [email protected]] From: David Ross Sent: Thur 9/17/2009 10:49:55 PM Subject: so sorry hey Jeffrey, I'm in London and just saw that stupid abortive deposition video on HuffPo. Damn, this was not what you needed or deserved. That lawyer was a complete asshole, and I think you handled yourself with dignity. Sorry to have seen this... but I know how tough you are, and in fact, it probably bothers me as your friend more than it does you. Thinking of you. Yours, David EFTA_R1_01509956 EFTA02437201