DataSet-9
Unknown
4 pages
From: Lesley Groff <1
To: George Delson
Subject: Re: Jeffrey Epstein
Date: Thu, 10 May 2012 16:39:07 +0000
ok, sounds good thanks
On May 10, 2012, at 12:38 PM, George Delson wrote:
Sony, Lesley. I didn't know Ave had sent it. I wanted to double check it. It should be correct but I will let you
know if there are any changes.
Joan
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 12:27 PM
Subject: Re: Jeffrey Epstein
tremendous! thank you so very much.
On May 10, 2012, at 12:23 PM, George Delson wrote:
Hi Lesley,
Attached is a count of Jeffrey's days through May. If you need anything further, let me know.
Ave
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
EFTA00413394
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:
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-
EFTA00413395
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:
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 41
To: George Delson & Associates Delson George
Sent: Thursday, May 10, 2012 8:05 AM
Subject: Jeffrey Epstein
EFTA00413396
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
EFTA00413397
DataSet-9
Unknown
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 Deposition Transcript
GJ SUBPOENA RESPONSE 000195 000262
August 7, 2009 Deposition Transcript
GJ SUBPOENA RESPONSE 000263 000336
September 8, 2009 Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 000337 000356
September 8, 2009 Deposition Transcript (Vol. II)
GJ SUBPOENA RESPONSE 000357 000495
November 23, 2009 Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 000556 000603
November 23, 2009 Deposition Transcript (Vol. II)
GJ SUBPOENA RESPONSE 000604 000651
February 16, 2010 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)
EFTA00078783
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, 201 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)
EFTA00078784
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)
EFTA00078785
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)
EFTA00078786
DataSet-9
Unknown
58 pages
Condensed Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
Plaintiff,
CASE NO.
-vs- 502008CA028051
X.XXXMB AD
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
LARRY VISOSKI
October 15, 2009
10:18 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida
Reported By: Wendy Beath Anderson
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIREa* Alexarter Gallo Coop or
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA01110326
Larry ViSOSki October 15, 2009
3
I P4 114£ CIRCUIT COURT OP TIM TIPTIMITE J-3DICIAL CIKUIT 1 • . -
IN MD IOR MLR REACH 010.TY, PLOPZDA
CASE MO. 5020010101POSIx110111 AD 2 INDEX
3 • • •
4
Plaintiff. 5 WITNESS: DIRECT CROSS REDIRECT RECROSS
6
JeFTISC nmxx. LARRY VLSOSK1
Defendant. 7
BY MR. EDWARDS: 6
MOOStt10N OP LAY vilest! a BY MR. CRITTON: 214
rIturenay, October 15. 3004 BY MR. EDWARDS: 220
toils - 1:11 pa. 9 BY MR. CRITTON: 221
10
511 N. Plagler Drive 11
Suite Me
Neer MIN. Satoh, florid.. 1)401 12 • • •
13 EXHIBITS
1141p9ftej Sy, 14 • • -
Wendy death Anderson, RPR, CRR. PPR 15
votary Public, State Of Plorida
,racialre Direesttlen Ninglowil 16 NUMBER DESCRIPTION PAGE
int pale brad, Office Jeb 113)541 17 PLAINTIFFS EX. 1 FLIGHT LOG BOOT(
(MARKED IN PREVIOUS DEPO)
28
19 PLAINTIFFS EX. 2 MESSAGE PAD 119
PLAINTIFF'S EX. 3 MESSAGE PAD 119
20 PLAINTIFF'S EX. 4 COMPLAINT 139
PLAINTIFF'S EX. 5 INMATE VISITOR LOG 161
21
22
23
24
25
2 4
APPEARANCES: 1 PROCEEDINGS
On behalf of the Plaintiff: 2 ...
BRADLEY J. EDWARDS. ESQUIRE
T ADLER 3 Deposition taken before Wendy Beath Anderson.
4 Certified Rash'rne Reporter and Notary Pudic in and for
5 the State of Florida at Large. in the above cause.
6 ---
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE 7 MR. EDWARDS: We're going to put something on
ITT 8 the record about -- well, we'll do it this way -
9 MR. REINHART: Do it at the end, alter we get
10 10 him -- whatever you want. It's your show.
12 On behalf of die Witness: 11
12 MR. EDWARDS: Okay. There were -- I don't
12 oven think Mr. Welds Is aware of this. There was
13 13 a subpoena duces team for this witness, as well as
1111= 14 the previous witness, which was another pilot. Dave
14
as ALSO PRESENT: is Rogers. and that duces tocurn was to bring the
16 MES E UtRE
16 flight logs related from 1998 through 2005. What
17 27 was produced at the previous deposition were flight
is
TIME i R WITZ PA. 1$ logs from 2002 through 2005, and now Mr. Reinhart
19 19 has agreed to produce the remainder of the flight
20 logs requested, those going from 1998 through 2002.
20
RICHARD H. WILLITS. ESQUIRE (VIA TELEPHONE) 21 MR. REINHART: Correct. They're pilot logs,
22 A P.A. 22 not night logs. There are other records we
22 23 Indicated are corporate records, and with those you
23 24 have to deal with Mr. Critton.
24
25 25 MR. CRITTON: However, with the proviso, too,
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE Oalloo ComPal
4440 PGA Boulevard
Palm Beath Gardens, FL 33410
vnvw.esquiresolutlons.com
EFTA01110327
Larry Visoski October 15, 2009
5 7
that we're going to work out that these records are 1 the question and you need to wait until I finish asking
to be used within the confines of this litigation 2 the question.
and not to be spread to the press or anyone else. 3 A. So yotfre not allowed to interrupt me?
because they do contain confidential information as 4 O. And you're not allowed to interrupt me.
to who may have been on the plane and other records 5 A. Like I just did?
of Mr. Rogers, which but for the subpoena would 6 O. Right.
have been only available to the FAA or some other 7 MR. CRITTON: Cara just snickered when you
law enforcement agencies. a said yotfve been accused because she recognizes
9 MR. EDWARDS: Okay. Is that all you want to 9 irs true.
10 put on? 13 MR. EDWARDS: I don't know what the meaning of
11 MR. CRITTON: Yes. 11 her snickering was.
12 MR. EDWARDS: I'm not saying I necessarily 12 BY MR. EDWARDS:
13 agree or disagree with you. Thais something that 13 Q. But for what ifs worth, if you don't
14 well deal with some other day. 14 understand the question or I've asked a bad question, I
15 MR. CRITTON: Bruce, you'd better produce 15 don't want you to guess. Give me the best answer to the
16 these records, but there has to be some sort of 16 best of your knowledge and if you need me to rephrase
17 understanding before - 17 rt. I wilt
18 MR. REINHART: Correct. 18 A. Okay.
19 MR. EDWARDS: I won't do anything until you 19 O. Okay. Tell me your current address.
20 file whatever you - until we work whatever it is 20 A
21 out in court. ill say that on the record, that
U
22 I'm not doing anything with the records outside of 22 Q. How long have you lived there?
23 my office until some Judge deals with It. 23 A. Approximately nine years.
24 MR. REINHART: And for the record, I'll adopt 24 Q. Okay. Who do you live there with?
25 what Mr. Craton said on this one limited occasion. 25 A. My wife and one chid al this tine.
6 8
MR. EDWARDS: Al right. 1 O. All right. How many children do you have?
2 Thereupon. 2 A. Two.
(LARRY VISOSKI) 3 Q. How old are they?
4 having been first duly sworn or affirmed, was examined 4 A. Fifteen and eighteen.
5 and testified as follows: 5 Q. And is the 18-year-old, is not living with
THE WITNESS: Yes, I do. 6 you?
DIRECT EXAMINATION 7 A. She's off in school.
8 BY MR. EDWARDS: a Q. Okay. What school Is that?
9 Q. Can you tell us your name for the record 9 A. Syracuse.
10 A. Lawrence Visoski, Jr. 10 Q. Who's your employer right now?
11 Q. And Mr. Visoski, have you ever had your 11 A. NES, LLC.
12 deposition taken before? 12 Q. How long has NES, LLC been your employer?
13 A. No. 13 A. I'm guessing. I'd say back 1991. I have to
14 O. Okay. Here's the process: I'm going to ask 14 do the math, but 17, 18 years.
15 you questions. You're going to give us answers. Try to 15 O. Has that been your only employer since 1991?
16 give us answers that we all understand and that the 16 A. Yes.
17 court reporter can take down, such as yes, no. or some 17 O. And has that been your only source of income
18 other verbal answer that we can understand. It's easy 18 since 1991?
19 when we get in a casual conversation to nod or shake 19 A. Yes.
20 your head, and the court reporter is not writing 20 Q. And what is NES, LLC?
21 pictures or anything else. 21 A. I don't really know. I mean, rt's the company
22 A. I understand. 22 that my check comes from.
23 O. The other thing is, and I've been accused of 23 Q. What do you do for NES, Lie that results in
24 this In other depositions -- I donl know if it's true 24 them paying you?
25 or not -- but I need to wait until you finish answering 25 A. I am chief pilot for the aircraft and
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIR
.m E 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
irnvw.esquiresolutIons.coM
EFTA01110328
Larry Visoski October 15, 2009
9 11
. helktopters. 1 O What floor or suite number is NES. LLC In?
0. And do you have a specific boss or somebody 2 A. I believe — well, I don't know that NES, LLC
you answer to at NES, LLC? A has an office there. I know that's where Leslie has the
A. Several people would call to schedule flights 4 phone number where I call So I don't know for a fact
from the office, being it either Mr. Epstein or, you 5 rf NES. LLC has an office there.
know. I would lust get a phone call and they would 6 O. And whet suite number, then, would Leslie
schedule a trip. 7 Gruff sit in to answer that telephone number at
Q. Okay. Aside from Mr. Epstein, who else would MIM
A. I think It's 10F.
9 there be that would call to schedule flights? 9
10 A Leslie. 10 Q. And when you stay a
11 0. Leslie who? 11 what suite number or what apartment number do you stay
12 A. Leslie Gruff. 13 in?
13 Q. When's the last time you talked to Leslie 13 A. 12C.
14 Gruff? 14 0. And how about Dave Rogers, where does he stay?
15 A. Probably two weeks ago, three weeks ago. 15 A. I'm guessing, because it's been some time
16 Q. And where is she currently? 16 since we've been there, 108, but don't quote me on
17 A. I believe in New York, is where I spoke to her 17 0. Who are the other people in that building that
18 on the phone last. 18 you know to stay there on a reguku — fairly regular
19 Q. What's the telephone number you call to reach 19 basis?
20 Leslie Gruff? 20 A. the seen people in the elevator that. you
21 A. 21 know, have been on the airplane. Case in point. maybe
22 Q. And what address is Leslie Gruff at? 22 but I dorYt know totaled that she Wes
23 A. Do you mean where the office Is located? 23 there, or anybody else for that matter.
24 0. Correct 24 0. Okay. When you say you've mein..
25 A. 25 on the elevator
10 12
1 0. And It's my understanding from other A. I only assume she Wes there. I don't know
2 depositions that there are also apartments In trial. 2 for a fact. rm hying to be honest and factual for
building? 3 you. So I couldn't honestly say if I knew she lived
4 A. Yes. 4 there or not
5 Q. And Mr. Epstein either owns or leases or rents 5 0. Where do you thine Wes?
6 certain of those apartments. Is that your 6 A. I would think she lives there.
7 understanding? 0. You don't have a bettor location?
a MR. CROTON: Form; speculation. 8 A. I don't have another location.
9 THE WITNESS: I'm only speculating. I 9 0. Anybody else?
10 don't -- to my understanding, I don't know. 2o A. Not to my knowledge. I mean, I'd only be
11 BY MR. EDWARDS: 11 guessing that people We in that builckng that -- you
12 0. Do you know other people that live in that 12 know, I don't have any facts to prove that they actually
13 building? 13 live there. I mean, I don't think you want me to guess.
14 A. Well, it would be myself. Dave Rogers - wet 0. Well, NES, LLC, would you say that the owner
35 when you say "live,' explain. 15 or controller of that company Is Jeffrey Epstein?
16 0. When you're saying yourself and Dave Rogers - 16 MR. CRITTON: Form.
17 A. See, we don't live there. I mean, we have -- 17 THE WITNESS: I don't know that for a tact.
18 we would stay there when we would have a trip. 1e BY MR. EDWARDS:
19 Q. Okay. When you would fly up to New York and 19 0. Jeffrey Epstein is somebody you've Indicated
20 land in New Yogic, the place where you would stay, is 20 that you've worked for for 17 or 18 years, right?
21 the 21 A, Yes.
22 A. Yes, that's corned. 22 0. And over the 17 or 18 years you've become
23 0. That's also a location you've indicated in 23 personally close with him as wee, correct?
24 this deposition that Is the office for NES, LLC? 24 MR. CRITTON: Form.
25 A. Yes. 25 THE WITNESS I Oaf* understand how you mean
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE •• SOM.!. Oal *U./al
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esqulresolutlons.com
EFTA01110329
Larry Visoski October 15, 2009
13 is
1 'dose.' Define that. 1 you know. televisions and such.
2 BY MR. EDWARDS: 2 O. Is that another hobby or job or something of
3 a Wel, rpm so than just a pilot that takes him 3 yours?
4 from Point A to Point B? 4 A. Both.
5 A. That is my job. 5 O. Does he pay you for that?
6 O. Right. But you know him on a personal level 6 A. Not any more than my salary.
7 and that you've had personal conversations that don't 7 O. What's your current salary?
8 necessarily deal with flying from Point A to Point B; A. At this time, 180,000.
9 isn't that right? 9 O. And what aro you paid $180,000 to do?
10 MR. CRITTON: Form. 10 A. To manage his aircraft.
11 THE WITNESS: More specific, meaning we talk 11 O. What does that entail?
12 about cars. I mean, does that make you a personal 12 A. Schedufing maintenance. Anything that has to
13 friends? 13 do with any flight, whether it be weather, flight
14 BY MR. EDWARDS: 14 planning, time and distance to and from a location, any
15 O. Have you ever gone to his house to eat? 15 logistics involved In running an operation that has
16 A. No. 16 aircraft.
17 O. Have you been to his New York home? 17 O. In addition to the 180,000, does he give yc.
18 A. Yes. 1$ bonuses as welt?
19 O. How many occasions have you been to his New 19 A. There have been Christmas bonuses.
20 York home? 20 O. Over the years, you mean, there have been
21 MR. CRITTON: Object to form. 21 Christmas bonuses?
22 THE WITNESS: We normally pick up luggage In 22 A. Yes.
23 the lobby, so it would probably be quite often. 23 O. Is 180,000 the most he's ever paid you?
24 Any time we depart out of New York, we stop by the 24 A. No.
2S house and pick up luggage and head to the aircraft. 25 O. All right Were you making when was the
14 16
BY MR. EDWARDS: 1 last time that you were making an amount different than
2 O. Other than picking up luggage, have you been 2 180,000?
3 to his home to visit or socialize with him? 3 A. Last year.
4 A. Not to socialize, no. 4 O. That would be 2008?
s a Have you been to his Palm Beach home? A. That would be correct. Yeah, we all took a
A. To? 6 salary cut, I don't know the exact date. It might have
O. To Mr. Epstoin's Palm Beach house? 7 been 2008, last year. It was last Christmas wo all took
8 A. Right. 8 a 10 percent salary cut.
9 O. Have you been there? 9 Q. Do you know why?
10 A. Yes. 10 A. Economic reasons.
11 O. Have you been inside? 11 O. And who told you that you were going to have
12 A. Yes. 12 to take the salary cut?
13 O. And how many occasions have you been inside 13 A. Darren Indyke.
14 that home? 14 Q. And did you ask for an explanation?
15 A. The same, as far as picking up luggage, and 15 A. lie explained it was due to economic reasons
16 that would be on a regular basis, you know, for a 16 throughout the country.
17 departure. We wouldn't always go to the house to pick 17 O. Okay. So In 2008, how much was -- were you
18 up luggage, but it made it easier for loading the 18 being paid by NES, LLC?
19 aircraft getting it done prior to departure. 19 A. 200.000.
20 Q. Is that the only reason that you have ever 20 O. And is 200,000 the most that you've ever made
22 gone to the Palm Beach home over the last 18 years. is 21 from NES, LLC?
22 to pick up luggage? 22 A. Yes. sir.
23 A. No. 23 O. And on top of that $200,000, did you get a
24 Q. What other reasons have you gone there? 24 bonus that year as well?
25 A I've set up several home theater equipments. 25 MR. REINHART: Which year are you bildng
Toll Free: 866.709.8277
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
veew.esquiresolutions.com
EFTA01110330
Larry Visoski October 15, 2009
17 19
about? 1 my paycheck. So I don't even know what's written on the
MR. EDWARDS: 2008. 2 lop of it.
THE WITNESS: That year, I think we skipped 3 0. That would be something that only your wife
Christmas bonuses that year. The last bonus might 4 would see. I'm assuming?
have been 2007. 5 A. You're right, since she probably wouldn't know
BY MR. EDWARDS: 6 the answer either, because she's looking et the right
Q. If you ever got a bonus from Mr. Epstein — 7 column and not the top column.
and I'm only deriving this from you using the term a 0. Right. When is the first time that you had
9 'Christmas bonus' 9 heard the name NES, LLC, that company?
10 A. Holiday bonus. 10 A. Fwe. Six years, and even questioned what'd
11 Q. -- am I correct to assume sorry. Am I 11 stood for. And I think to this day I couldn't answer
12 correct to assume that if you got a bonus, there was 12 that honestly, what It stands for.
13 only one and it was at the end of the year, around the 13 0. Okay. But it's your understanding that the
14 holidays? 14 NES, LLC is paying you for the work that you do as a
15 A. Yes. 15 pilot or maintain the planes for Jeffrey Epstein?
16 Q. Okay. And how much was the 2007 holiday 16 A. To my understanding, yes.
17 bonus? 17 a And back In 1991. do you know If It was a
18 A. I'd have to ask my wife. to be honest. I 18 dffereert company that was paying you or if it was
19 haven't seen my paycheck in 27 years. so I believe it 19 Jeffrey Epstein directly paying you?
20 was 310.000. 30 A. I don't remember. I mean, I don't
21 Q. And in 2007 you also made $200,000? 21 0. Okay. Throughout your career with -- as a
22 A. Yes. 22 pilot laJeffrey Epstein, since 1991, has there ever
23 Q. Okay. 23 been a time when you believe you we paid directly from
24 A. With a question mark. I'm trying to be as 24 Jeffrey Epstein personally versus some company?
25 accurate as I can, but yes. 25 A. Not to my kncrertedge, no.
18 20
0. Something pretty close to mat? 0. Okay. So whether s was NES. LLC or some
A. Yes, sir. 2 other company, it was all of a sudden a company name, to
0. Okay. So with the bonus it was 210,000. 3 the best of your linoviedge?
roughly? 4 A. Exactly, yes.
5 A. Right. 5 0. And back in 1991, do you remember
0. Okay. And how long were you making that 6 approximately how much you were being paid that year?
salary? 7 A. Fifty-live or 80.000. is maybe what I started.
A. Probably -- he was very religious about giving 8 0. Okay.
9 annual increases. so I would probably say 2006, you A. You're going back a long ways.
10 know. It was -- we would get Increment increases of 10 0. Yes.
11 five or $10,000 each year. So I would say 2006. So it 11 A. I'm trying.
12 graduated. you know, progressive. 13 0. Your relationship goes back that far. There
13 0. Okay. Do you remember the progression if we 13 why I those that year.
14 start at 1991? Do you remember roughly what the 14 A. Right.
15 progression was up through 2007/2008, when you were 15 0. Okay. Did you get bonuses even back that far?
16 making $200,000? 16 A. Yes, sir.
17 A. No, I wouldn't know the progression. 17 0. And do you remember what your bonuses were
15 0. Okay. Do you remember what you were making as approiknately?
19 from -- and was NES, LLC the company paying you back in 19 A. 5,000. I mean. that was laird of the — the
20 1991? 20 starting point.
21 A. I don't know. I don't remember. Let me say 21 0. Okay. In addition to moneary bonuses. were
22 it that way. I don't remember. 22 there ever gifts or any other type of compensation that
23 O. Okay. When how long do you remember NES, 21 NES, LLC or Jeffrey Epstein provided you?
24 LW being the payer of your check? 24 A. Yes.
25 A. Personally, two years. because I've never seen 25 0. And is that over the span of the 18 years?
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE a* A nat. Gall* Ceasan
4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutIons.coM
EFTA01110331
Larry Visoski October 15, 2009
21 23
A. Yes. 1 Q. But more so than that, if there's going to bo
O. Okay. Ten me what some of those items are. 2 a casual conversation about a peel or a pool heater or
A. I remember one specifically was a pool heater. 3 whatever, Ws going to be with you most likely if he's
Q. Excuse me? 4 going to be talking to pilots, right?
A. A pool heater. 5 MR. CRITTON: Form.
Q. When was that? 6 THE WITNESS: Right.
1995-ish. 7 BY MR. EDWARDS:
Q. Okay. Why did you get that? O. Okay. And you feel like over the years yoke
9 A. I had built a pool and I didn't have a heater 9 relationship with Jeffrey Epstein has boon pretty good?
10 and he kind of laughed at me saying, 'How can you have a 10 A. Yes.
11 pool without a heater?' So he says, 'You ought to get a 11 O. And you have been closer to him over the years
12 heater." 12 as you've grown to know him?
13 Q. Where were you when you had that conversation? 13 MR. CRRTON: Form.
14 A. In the airplane. 14 THE WITNESS: The same throughout the same
15 O. How ofd he know that you had bunt a pool? 15 year. We never got any closer than 1991 than I am
16 A. Just in general conversation, 16 wilt him now. I'm very professional at what I do
17 O. You were having a conversation with Jeffrey 17 and know the line between being professional and
18 Epeteli? 18 thinking you're somebody's buddy.
19 A. Yes. 19 BY MR. EDWARDS:
20 O. And this is something that was happening on 20 O. Okay. So thars not something that you think
21 the airplane, this conversation? 21 you are? You don't think you're his buddy?
22 A. Dung the flight Yeah, It would have been 22 A. No, sir.
23 We on cruise or something. 23 O. Do you consider yourself his friend?
24 Q. Okay. When you say during the flight,' does 24 A. I believe so.
2s that — 25 Q. Do you think he considers you his friend?
22 24
A. Again, you're going back a long ways. 1 A. I think so.
2 O. I understand. We're larking about 1995 right 2 O. All right. What makes you think that?
now. 3 MR. CARTON: Speculation.
A. Yes. 4 THE WITNESS, He's always been kind and
5 O. You're having a conversation with Jeffrey 5 respectful.
6 Epstein. Who is flying the airplane? 6 BY MR. EDWARDS:
7 A. The auto pilot and there's two crew. O. Ever invited you to dinner?
8 O. Okay. So are you back in the back portion or A. No, sir.
9 Is he up In the cockpit? 9 Q. Have you ever associated or socialized with
10 A. Up in the cockpit. t0 him during the day at any of his homes?
11 O. Okay. Jeffrey Epstein sometimes comes up 11 A. Only during a business reason.
12 there? 12 O. Okay. What are the other are the places
13 A. Just, yeah, in between the two pilot seats. 13 that you believe that Mr. Epstein owns? I know we've
14 Q. All right. Is that something that was 14 talked about this Manhattan -- the Manhattan house.
15 typical, to have conversations like that? IS I've read the altos about it, the Palm Beach mansion.
16 A. Mm-hmm. 16 But what other places are you familiar with that
1? O. Yes? 17 Mr. Epstein owns?
18 A. Yes. No nodding. 18 MR. CRITTON: Form; predicate, speculation.
19 O. And woukl those conversations be directed 19 THE WITNESS: To answer it honestly. I don't
20 mainly with you or with the other pilots as well? 20 know specifically that he owns any of the
21 A. Mainly with me. 21 residences, to be honest. I would only assume that
22 Q. I mean, you've kind of been described as the 22 he owns. So if you want me to answer honestly. I
23 main guy or the main pilot. Wouldn't you consider that 23 don't know that he owns any of the other.
24 pretty much your role, right? 24 BY MR. EDWARDS:
25 A. Well, that's chief pia 25 Q. Okay. Well, what would be the basis for your
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIR
nA""...“E
_."
4440 PGA Boulevard
Palm Beach Gardens, Ft. 33410
www.esquiresolutlons.com
EFTA01110332
Larry Visoski October 15, 2009
25 27
assumption that he owns the home in Pakn Beach? 1 O. Am those private airports?
2 A. He goes there, but I don't assume -- you don't 2 A. Public.
a have to own a house to go to it. 3 O. Public, okay. Are there any private landing
Q. And not only does he go there, you're aware places where you would land any airplanes in New Mexico?
that he spends the night there: he resides there 5 A. There are.
6 sometimes, correct? 6 0. That you have landed
A. Yes. 7 A. That I have.
5 0. When he's in Palm Beach, Mat's where he — 0. - his airplane?
9 A. He sloops. 9 A. Yes.
10 0. sleeps? Right. When he's in New York, do 10 0. Where?
11 you know where he sleeps? 11. A. We have a 4500-foot strip on the ranch.
12 A. No. 12 0. When you say 'we.' yourself and somebody'
13 Q. But you've been to a particular house in New 13 A. The company.
14 York that's a very large house that we've all read about 14 Q. What company?
15 that you picked up luggage at, right? 15 A. Well. I should say I see where you're going
16 A. Yes, sir. 16 waft that. The ranch owns — whoever owns the ranch.
17 MR. CRITTON: Form. 17 The ranch has a runway on it.
18 BY MR. EDWARDS: 16 Q. Okay. And you've landed an airplane on that
19 0. And that home, do you know that — I know that 19 noway?
20 you're saying that you haven't done a public record 20 A. That ranch. yes.
21 search to make sure that Jeffrey Epstein owns it. 21 Q. How many times do you think you've landed
22 A. Yeah. 22 there?
23 0. But you assume that he does? 23 A. Ten.
24 A. Assuming. 24 Q. All right. And have you been inside his
25 0. That's where he sleeps when he's in New York? 25 ranch?
26 28
MR. CRITTON: Form. 1 A. Yes.
2 THE WITNESS: I assume. 2 MR. CRITTON: Form to the last question.
3 BY MR. EDWARDS: 3 MR. REINHART: Can you clarify, the physical
4 0. That's where his luggage is when you pick it 4 ranch or the residences or the structures on the
up? 5 ranch?
6 A. Doesn't mean he owns It. 6 MR. EDWARDS: I don't have a good visual
0. Right. But that's where it is? 7 appreciation for it.
A. Yes, sir. 8 BY MR. EDWARDS:
9 0. Do you know of anybody else who owns that home 9 Q. Why don't you describe it in your words what
10 in New York? 10 this ranch Mal We are talking about looks like. And
11 A. No. 11 I've heard it referred to as the Zorro Ranch. Have you
12 0. Okay. Have you been to his ranch in New 12 heard that?
13 Mexico? 13 A. I've heard that.
14 A. Yes. 14 0. That's the ranch we're all familiar with,
15 MR. CFUTTON: Form. 15 we're talking about where the runway is and everything
16 BY MR. EDWARDS: 16 else?
17 0. How many times have you been to his ranch in 17 A. Yes.
18 New Mexico? 18 0. Describe it in your own words, the landscaping
19 MR. CRITTON: Form: predicate. 19 of this ranch. What do we have on it?
20 THE WITNESS: A guesstimate. fifty times, only 20 A. There is a house up on the hal, a large
21 due to the fact that we would fly there. 21 house.
22 BY MR. EDWARDS: 22 O. How big?
23 0. And where would you land? 23 A. Big. I've read 40,000 square feet In the
24 A. Depending upon the aircraft, either 24 paper.
25 Albuquerque or Santa Fe. 25 O. Have you been to it?
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquIresolutions.corn
EFTA01110333
Larry Visoski October 15, 2009
29 31
1 A. Yes. 1 A. Yes. sir.
2 Q. Does that seem like it's feasible, 2 Q. And he sleeps there?
3 approximately 40,000 -- 3 A. Yes.
4 A. I think so. yes. 4 Q. Okay.
5 Q. What else do we have on it? A. I assume he does.
6 A. There Is a compound that hes kind of motel 6 0. You assume he sleeps?
7 room type -- they call it bunkhouse. 7 A. I do. I think.
8 0. Where's the bunkhouse located? 8 Q. Okay.
9 A. At the entrance to the ranch. 9 MR. CRI1TON: This Is really --
10 0. Okay. And what Is that primarily used for? 10 BY MR. EDWARDS:
11 A. For the people that work on the ranch, they 11 0. Other than the pool heater in 1995. have you
12 reside there. It's also a place where anybody that 12 ever received any other gifts on top of the compensation
13 traveled on the airplane would stay. It's lTd of Eke, 13 from Mr. Epstein?
14 you know, a hotel room. 14 A. I did get land on the ranch to build a house.
15 0. And how far is that from the first house that 15 Q. What do you mean you got land on the ranch?
16 you deserted, the 40.000 square foot house? 16 A. He deeded me land to build a home.
17 A. Its probably 4 miles. 17 Q. When was that?
is Q. Okay. So the Zone Ranch is a rather large 1$ A. Ten years ago at least
19 area of property? 19 Q. Do you know 4 he's ever deeded anyone else in
20 A. Yes. 20 this world land on the ranch to bultd a home?
DataSet-9
Unknown
2 pages
From: Lesley Groff
To: Greg Wyler
Subject: Re: Jeffrey Epstein
Date: Tue, 08 Apr 2014 18:18:45 +0000
tremendous. thanks
On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote:
> My cell is:
> 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
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,
EFTA00371303
» Lesley
>> Assistant to Jeffrey Epstein
>>
>>
>
>
EFTA00371304
DataSet-9
Unknown
7 pages
IN THE CIRCUIT COURT OF THE 15T"
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
DRAFT 11/21/10 COMPLEX LITIGATION FLA.R.CIV. P. 1201
CASE NO. 50 2009CA 0400XXXXMB AG
JEFFREY EPSTEIN,
Plaintiff,
v.
SCOTT ROTHSTEIN, individually, BRADLEY
J. EDWARDS, individually, and
individually,
Defendants.
PLAINTIFF'S MOTION TO STRIKE EXHIBITS AND
ATTACHMENTS TO DEFENDANT
EDWARDS'S MOTION FOR SUMMARY JUDGMENT
Plaintiff Jeffrey Epstein ("Epstein") moves, pursuant to Rule 1.510 of the Florida Rules of
Civil Procedure, to strike the unswom and otherwise unauthenticated "Exhibits" and "Attachments"
to the allegedly "Undisputed Statement of Facts" filed and served by defendant Bradley J. Edwards
("Edwards") and upon which Edwards relies to support his Motion for Summary Judgment. The
specific grounds for this Motion are:
1. On September 22, 2010, Edwards served a Motion for Summary Judgment (the
"Summary Motion") seeking to have this Court conclude that there is no genuine issue of material
fact as to each count against him and to grant him judgment on the claims raised against him by
Epstein in this action.
2. Edwards filed a 37-page "Statement of Undisputed Facts," consisting of 120 separate
paragraphs, most of which are either not material at all or, where they are conceivably material, they
EFTA01128700
CASE NO.50 2009CA 0400XXXXMB AG
are disputed. Arguably, only paragraphs 86 through 91 bear on the subject of this lawsuit.'
3. In support of these 120+ allegedly "undisputed" facts, Edwards served an eight inch
tall stack of "47 exhibits" and 22 "attachments" numbered respectively from "A" to "UU" and "1"
to "22". Collectively, we refer to these materials as the ("Supporting Papers").
4. Among these Supporting Papers are 22 transcripts of depositions or excerpts of
depositions — the "Attachments," most of which were taken prior to the filing of this action in 2009
and before. The other "Exhibits" are a compendium of unworn letters, pleadings and other court
filings, hearing transcripts, an unauthenticated copy of what purports to be a plea agreement between
Scott Rothstein and the government,' unsigned drafts, unsigned answers to interrogatories from
another case, New York Post and other media publications, items (such as phone messages) allegedly
garnered from Plaintiff and others pursuant to search warrants in criminal investigations of Plaintiff,
a purported copy of a visitor log from the Palm Beach County Sheriff's Office, flight logs, and other
Nevertheless, Edwards fills 35 pages with facts that are not material to any issue in this
case for the apparent purpose of prejudicing Plaintiff in this Court with a gratuitous and graphic
recount of conduct and alleged conduct not in issue in this case, such as Plaintiff's alleged sexual
exploits with clients of Edwards. There can be no other reason.
2 See Exhibit "SS." The statement of facts incorporated into the plea agreement refers
throughout to Rothstein and "other co-conspirators" without naming those others. It intimates that
others working in the Rothstein Rosenfeldt and Adler firm knew of the Ponzi scheme and conspired
to advance the criminal enterprise. Plaintiff believes Edwards is such a person, notwithstanding
Edwards production of an unswom form letter from a federal victim witness specialist identifying
him as a possible victim of Rothstein (exhibit `IT"), but has not yet been provided the documentary
evidence he has been seeking to use against Edwards.
2
EFTA01128701
CASE NO.50 2009CA 0400XXXXMB AG
documents the materiality of which is not facially apparent.'
5. All of the Supporting Papers, except Exhibits "N," fail to conform to the Florida rules
of civil procedure and must be stricken.' The Supporting Papers have not been certified, verified
or properly authenticated.
6. The law in the Fourth District, as well as in Florida's other courts of appeal, clearly
and unconditionally provides that unauthenticated documentary evidence may not be relied on or
considered in support of a motion for summary judgment. See Hollywood Towers Condominium
Association, Inc. v. Hampton, 993 So. 2d 174, 175-176 (Fla. 4th DCA 2008) (unauthenticated
photocopies of check, letter and bank statement attached to motion for summary judgment could not
be used to support motion); Bifulco v. State Farm Mutual Auto. Ins. Co., 693 So. 2d 707, 710 (Fla.
4th DCA 1997) (trial court could not consider unswom or uncertified insurance documents attached
to motion for summary judgment); Mack v. Commercial Industrial Park Inc., 541 So. 2d 800 (Fla.
3 For example, Attachment "1" purports to be a 183-page deposition of Plaintiff in a case
styled v. Jeffrey Epstein then pending in this Court, but the copy of the transcript is not signed
and certified by the court reporter or otherwise authenticated and is therefore inadmissible.
Attachment "2" consists of an excerpt of 9-pages of the purported transcript of a deposition of a Jane
Doe which apparently in its entirety is more than 568 pages in length. Edwards included those pages
to support the statement that Jane Doe was abused at least 17 times. It actually does not support that
statement, but regardless, the excerpt is not in any way authenticated. Attachments 3 through 22
suffer from the same defect. The exhibits with the exception of "N" are no better.
4
This exhibit is the Affidavit of Defendant Edwards which appears to have been sworn in
conformance with Florida statutes, although much of what is sworn to is immaterial or disputed.
Attachment 15 is not certified, appears to be a complete transcript (not an excerpt) and bear the
signature of a court reporter, but it hardly material. See Statement of Undisputed Facts at paragraph
57. Exhibit "QQ" is a sworn affidavit; however, it consists almost entirely of hearsay and double
hearsay and must be stricken.
3
EFTA01128702
CASE NO.50 2009CA 0400XXXXMB AG
4th DCA 1989) (contractual exhibits which were unaccompanied by an affidavit could not be
considered in support of motion for summary judgment)? In Bifulco, the court of appeal observed:
[lJt is unquestionably clear that the documents attached to Appellee's motion are not
sworn to or certified in any manner whatsoever, nor are they in proper admissible
form. They are not accompanied by any affidavit of a records custodian or other
proper person attesting to their authenticity or correctness. .. . They were received
without any foundation other than the representations of Appellee's counsel. In short,
rule 1.510(e), by its very language, excludes any document from the record on a
motionfor summaiyjudgment that is not one of the enumerated documents or is not
a certified attachment to a proper affidavit The documents in question in the case
before us, standing by themselves, are insufficient to satisfy the heavy burden
Appellee must meet in order to juste the granting ofsummayyjudgment in itsfavor.
693 So. 2d at 710 (emphasis added)?
7. Here, it is unquestionably and undeniably clear that none of the Supporting Papers
save two, are sworn or certified in any manner whatsoever.' They likewise are not accompanied by
an affidavit of a records custodian or other person attesting to their authenticity, completeness or
correctness. Each of these 67 Supporting Papers is therefore "insufficient" to support Defendant
s
Other courts of appeal have held the same. See, e.g., Nichols v. Preiser, 849 So. 2d478, 481
(Fla. 2d DCA 2003) (trial court could not consider letters that were not sworn or certified); First
Union National Bank ofFlorida v. Ruiz, 785 So. 2d 589, 591 (Fla. 5th DCA 2001) (unswom EEOC
letter did not satisfy procedural strictures inherent in Rule 1.510(e)); Brooker v. Sarasota, Inc., 707
So. 2d 886, 887 (Fla. 1st DCA 1998) (trial court could not consider unauthenticated document in
ruling on motion for summary judgment).
6 Rule 1.510(e) requires that "[s]worn or certified copies of all papers . . . referred to in an
affidavit shall be attached thereto or served therewith." See also First North American National
Bank v. Hummel, 825 So. 2d 502, 504 (Fla. 2d DCA 2002) (party opposing motion for summary
judgment could not rely on documents that were not authenticated or supported by an affidavit or
other evidentiary proof); Tunnel v. Hicks, 574 So. 2d 264, 266 (Fla. 1st DCA 1991) (same).
The transcripts, no doubt, could be certified but they are not.
4
EFTA01128703
CASE NO.50 2009CA 0400XXXXMB AG
Edward's heavy burden of proof and this Court cannot rely on them to justify a grant of summary
judgment. Id.
8. Moreover, the Supporting Papers constitute inadmissible hearsay and the statements
within them cannot be considered for the truth. None (except Exhibit "N") has been authenticated
by anyone in an attempt to lay the required foundation for their admissibility as either public records
or business records. See Biluko, 693 So. 2d at 710-711 (insurance documents attached to motion
for summary judgment were inadmissible under business records or public records exceptions to
hearsay rule where required predicate was not established); Gray v. State, 910 So. 2d 867, 869 (Fla.
1st DCA 2005) (document on Department of Corrections letterhead was hearsay where foundation
not laid for its admission as a business record or a public record); see also Adams v. State, 521 So.
2d 337, 338 (Fla. 4th DCA 1988) (business records are inadmissible without a proper foundation for
their admission).
9. The Supporting Papers therefore constitute unauthorized and improper
unauthenticated documentary evidence which must be stricken from defendant Edwards's Statement
of Undisputed Facts that allegedly support his Motion for Summary Judgment and which cannot
properly be considered by this Court in support of the Summary Motion.
WHEREFORE, based on the foregoing, PlaintiffJeffrey Epstein respectfully requests that
this Court enter an Order striking Exhibits "A" through "M" and "O" through "UU," as well as
Attachments numbered "1" through "22," allegedly offered in support of Defendant Bradley J.
Edwards's Statement of Undisputed Facts submitted with his Motion for Summary Judgment as to
all claims against him, and grant such other and further relief to Plaintiff as the Court deems
5
EFTA01128704
CASE NO.50 2009CA 0400XXXXMB AG
appropriate.
Respectfully submitted,
Joseph L. Ackerman, Jr.
Florida Bar # 235954
Christopher E. Knight
Florida Bar #607363
FOWLER WHITE BURNETT, P.A.
Attorneysfor Plaintiff Jeff Epstein
Phillips Point, West Tower
777 South Flagler Dr., Suite 901
W. Palm Beach, FL 33401
6
EFTA01128705
CASE NO.50 2009CA 0400XXXXMB AG
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing Plaintiff's Motion to Strike Exhibits to
Defendant Edwards's Motion for Summary Judgment was served by this day of
November, 2010 on:
Jack Scarola
Searcy Denney Scarola Barnhart & Shipley
Attorneysfor Bradley J. Edwards
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Marc S. Nurik,
Law Offices of Marc S. Nurik
Attorneysfor Scott Rothstein
One E. Broward Blvd., Ste 700
Fort Lauderdale, FL 33301
(as] WN307.131motion to strike etlw aj •upmn.sua 1 1/21/10.22291
7
EFTA01128706
DataSet-9
Unknown
1 pages
From: Lesley Groff 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
EFTA00371565
DataSet-11
Unknown
7 pages
1 OF 2 150526 WRO F381 PIC0092015
WORK REQUEST ORDER
PICTON II LTD
VP-BBJ 16737-72U I SN 29273 I YG006
NC I E2T I E2C I APUT I APUC
I
TO: FROM (CAM):
Seyidi Ersevik Steve Wilson
COMPANY: DATED:
hit Aviation Geneva 76.05.7014
FAX NUMBER: QUOTATION REFERENCE:
NJA
EMAIL ADDRESS: WORK REQUEST ORDER NUMBER:
P1C0092015
W/O ENTRY
ITEM DESCRIPTION
SIGNATURE
1. Comply with 1A/2A CAMP WO attached - -VP-BB) 2A Check 2015".
Comply with Due Maintenance CAMP WO attached - "VP-BB) Due MX Jun 2015".
2. Compliance with AD 2012.24.08 / SB 737-30A1063 R2
NOTE: KITS provided as ordered with Jet Aviation.
AMOC Letters to be referred if SB 737.30A1063 is not possible to install as is.
(AMOC letters:
I. GAMOC_1305-13-254
2. GAMOC_1305.14-66
3. SB-737-30A1063-02-AMOC-01 = 36 Months
3. Compliance with Task 28-AWL-05 and any other A/R applicable task after AD 2012-24.08 C/W.
4. Compliance with AD 2010-24-11 / SB 737.57A1279 consumables to be ordered ASAP.
NOTE: A/R Tasks (MPD) to be verified N/A before access closure.
S. Compliance with AD 2012-25-05 N/A by PN installed. Please check aircraft and record in WO
accordingly.
6. Compliance with SB 737-28A1206 R3. Revision 2 previously C/W.
7.
THANK YOU
EXPECTED ARRIVAL: 15.06.2015
REQUESTED AVAILABILITY: 26.06.2015
CONTINUED AIRWORTHINESS MANAGEMENT (on behalf of PICTON II Ltd)
Qjet Aero I Switzerland I [email protected] I Tel: +41 76 510 2654
EFTA_R1_02140495
EFTA02714500
150526 WRO F381 PIC0092015
WORK REQUEST ORDER
INSTRUCTIONS RELEVANT - CERTIFICATE OF RELEASE TO SERVICE (CRS)
1. After entry of Work Request Items into MRO system, Planning or Technical
Support shall sign in the allocated space. Signature indicates that request(s)
have been transferred to the actual project.
2. Item numbers showing "*" have been amended/added after original order
was issued.
3. Certificate of Release to Service (CRS) shall refer Work Request Order
Number and encompass all requested items unless otherwise specified or
communicated.
4. Work Order entries (items) shall detail maintenance reference/specific
chapters in all cases. Generic references and vague statements will not be
accepted. AMM revision status shall also be indicated.
5. CRS shall comprise Flight Log Entry/Stamp/Signature and printed Certificate
for Aircraft/Engine/APU Logbook(s).
INSTRUCTIONS RELEVANT - CONTINUED AIRWORTHINESS MANAGEMENT
1. Before aircraft departure CRS, WO and Flight Log Entry shall be scanned and
sent to the Continued Airworthiness Manager (CAM) for review.
2. After project closing, all CAMP Cards including CRS shall be scanned and sent
to CAMP SYSTEMS for update within 5 working days.
3. Original Work Package documents shall be handed to the Operator or CAM as
arranged.
Note: There is no requirement for originals/copies of procedures used during
maintenance to be provided.
CONTINUED AIRWORTHINESS MANAGEMENT (on behalf of PICTON II Ltd)
Qjet Aero I Switzerland I [email protected] I Tel: +41 76 510 2654
EFTA_R1_02140498
EFTA02714501
CAMP
A^....P•••••••••••ey
Work Order Contents Report
SERIAL : 29273 (YG006) REGNO : VP-BBJ MODEL NAME : BBJ 737-700IGW/-800/-900ER WORK ORDER A: VP-BB.1 2A CHECK 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.0 050020 A-2 CHECK OPEN
1.1 352003 VISUAL INSPECTION OXYGEN SYS. BOX(S) OPEN
1.2 352004 VISUAL INSPECTION OXYGEN SYS MASK(S) OPEN
1.3 21-88)-01 INSPECT AND CLEAN OR REPLACE THE LEFT HAND NC COALESCER BAG OPEN
1.4 21-88)-02 INSPECT AND CLEAN OR REPLACE THE RIGHT HAND NC COALESCER BAG OPEN
1.5 33-090-00 GENERAL VISUAL INSPECTION OF THE TRANSPARENT FAIRING LENS LOCATED ON THE FORWARD LEADING OPEN
EDGE OF THE WINGLET, LEFT AND RIGHT
1.6 25-020-00 DETAIL INSPECTION OF PIE CAPTAIN, FIRST OFFICER, FIRST OBSERVER AND SECOND OBSERVER (IF OPEN
INSTALLED) SEAT HARNESSES, CROTCH STRAPS, AND SHOULDER BELTS (AS APPLICABLE) FOR WEAR,
CONDITION AND SECURITY.
1.7 28-20-01 PATS OPERATIONAL CHECK OF THE AUXILIARY FUEL CONTROL UNIT OPEN
1.8 23-110-00 (FAR 91.207) INSPECT (FIXED) EMERGENCY LOCATOR TRANSMITTER TAW FAR 91.207(D) OPEN
1.9 54.090-01 FUNCTIONALLY CHECK THE LEFT ENGINE FORWARD STRUT AND AFT STRUT MIRING DRAINS. OPEN
1.10 54-090-02 FUNCTIONALLY CHECK THE RIGHT ENGINE FORWARD STRUT AND AFT STRUT MIRING DRAINS. OPEN
1.11 385015 CLEAN AFT GALLEY SINK DRAIN FILTER OPEN
1.12 21-140-01 CHECK THE LEFT WATER SEPARATOR INDICATION DISK (WITH THE AIR CONDITIONING SYSTEM OPERATING) OPEN
1.13 21.140.02 CHECK THE RIGHT WATER SEPARATOR INDICATION DISK (WITH THE AIRCONDITIONING SYSTEM OPERATING) OPEN
1.14 23-040-00 OPERATIONAL CHECK OF THE VOICE RECORDER AND RECORDER INDEPENDENT POWER OPEN
SUPPLY (RIPS) (IF INSTALLED).
1.15 27-102-00 LUBRICATE STABILIZER TRIM ACTUATOR AND ACTUATOR GIMBAL PINS AND BALLNUT OPEN
1.16 27-170-01 LUBRICATE LEFT WING TRAILING EDGE FLAP ACTUATION MECHANISM OPEN
1.17 27-170-02 WBRICATE RIGHT WING TRAILING EDGE FLAP ACTUATION MECHANISM OPEN
L18 32-010-01 CLEAN LEFT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.19 32-010-02 CLEAN RIGHT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.20 32-020-01 SERVICE LEFT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.21 32-020-02 SERVICE RIGHT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.22 32-030-01 LUBRICATE LEFT MAIN LANDING GEAR ASSEMBLY OPEN
1.23 32-030-02 WBRICATE RIGHT MAIN LANDING GEAR ASSEMBLY OPEN
1.24 32-060-00 CLEAN NOSE LANDING GEAR SHOCK STRUT OPEN
1.25 32-070-00 SERVICE NOSE LANDING GEAR SHOCK STRUT OPEN
1.26 32-080-00 LUBRICATE NOSE LANDING GEAR ASSEMBLY OPEN
1.27 32-270-01 VISUAL CHECK LEFT BRAKE WEAR PINS FOR MINIMUM EXTENSION OPEN
1.28 32-270-02 VISUAL CHECK RIGHT BRAKE WEAR PINS FOR MINIMUM EXTENSION OPEN
1.29 32-800-00 EXTERNAL ZONAL INSPECTION (GV) NOSE LANDING GEAR AND LANDING GEAR DOORS (FROM GROUND) OPEN
PERFORM AN EXTERNAL ZONAL INSPECTION (GV) Of THE NOSE LANDING GEAR AND LANDING GEAR DOORS.
INSPECTION IS ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. (EZAP)
1.30 32.804.01 EXTERNAL ZONAL INSPECTION (GV) LEFT MAIN LANDING GEAR AND LANDING GEAR DOORS (FROM GROUND) OPEN
PERFORM AN EXTERNAL ZONAL INSPECTION (GV) OF THE LEFT MAIN LANDING GEAR AND LANDING GEAR
DOORS. INSPECTION IS
ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS
1.31 32.808.02 EXTERNAL ZONAL INSPECTION (GV) RIGHT MAIN LANDING GEAR AND LANDING GEAR DOORS (FROM GROUND) OPEN
PERFORM AN EXTERNAL ZONAL INSPECTION (GV) OF THE RIGHT MAIN LANDING GEAR AND LANDING GEAR
DOORS. INSPECTION IS
ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS
26-MAY-2015 © CAMP SYSTEMS I of 3
EFTA_R1_02140497
EFTA02714502
CAMP
A^....P•••••••••••ey
Work Order Contents Report
SERIAL : 29273 (YG006) REGNO : VP-BB) MODEL NAME : 68) 737.700IGW/-800/-900ER WORK ORDER At: VP-B8) 2A CHECK 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.32 33-010-00 OPERATIONAL CHECK EMERGENCY LIGHTS OPEN
1.33 53-800-00 EXTERNAL ZONAL INSPECTION (GV) OF THE LOWER FUSELAGE. THE NOSE LANDING GEAR WHEEL WELL AND OPEN
MAIN LANDING GEAR WHEEL WELL ARE ALSO INCLUDED. INSPECTION IS ACCOMPLISHED FROM THE GROUND,
WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED (EZAP)
1.34 53.81200 INTERNAL ZONAL INSPECTION (GV) FORWARD CARGO COMPARTMENT - SECTION 43, STATION 396 TO OPEN
FORWARD CARGO COMPARTMENT AFT BULKHEAD
1.35 53-830-00 INTERNAL ZONAL INSPECTION (GV) AFT CARGO COMPARTMENT - SECTION 46 AND 47 (PART), STATION 727 OPEN
TO STATION 947.5
1.36 53.84400 EXTERNAL ZONAL INSPECTION (GV) OF THE WING TO BODY FAIRING. INSPECTION IS ACCOMPLISHED FROM OPEN
THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRE
1.37 53-894-00 EXTERNAL ZONAL INSPECTION (GV) OF 711E FUSELAGE. INSPECTION IS ACCOMPLISHED FROM THE GROUND, OPEN
WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED
1.38 55-800-00 EXTERNAL ZONAL INSPECTION (GV) VERTICAL FIN AND HORIZONTAL STABILIZER. INSPECTION IS OPEN
ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS
PANELS REQUIRED
1.39 57.802-01 EXTERNAL ZONAL INSPECTION (GV) LEFT WING INSPECTION IS ACCOMPLISHED FROM THE GROUND, WITHOUT OPEN
THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED.
1.40 57-872-02 EXTERNAL ZONAL INSPECTION (GV) RIGHT WING INSPECTION IS ACCOMPLISHED FROM THE GROUND, OPEN
WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED.
1.41 70-803-01 EXTERNAL ZONAL INSPECTION (GV) NO. 1 ENGINE STRUT FAIRINGS. INSPECTION IS ACCOMPLISHED FROM OPEN
THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO
ADDITIONAL ACCESS PANELS REQUIRED.
1.42 70-810-02 EXTERNAL ZONAL INSPECTION (GV) NO. 2 ENGINE STRUT FAIRINGS INSPECTION IS ACCOMPLISHED FROM OPEN
THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO
ADDITIONAL ACCESS PANELS REQUIRED
1.43 52-150-00 LUBRICATE AIRSTAIR DOOR SYSTEM (INCLUDES TWO ROLLERS, CARRIAGE DRIVE BEARING, DRIVE NUT IN OPEN
JACK SCREW, LOCK PIN GREASE FITTING AND FOUR BEARINGS IN THE CARRIAGE ROLLERS).
1.44 26-450-00 INSPECT (DETAILED) THE PORTABLE HALON FIRE EXTINGUISHERS FOR PROPER PRESSURE (IF GAUGE OPEN
INSTALLED), WEIGHT AND CONDITION.
1.45 050010 A- I CHECK OPEN
1.46 257001 GENERAL VISUAL INSPECTION HEADLINER CEILING PANELS OPEN
1.47 257002 GENERAL VISUAL INSPECTION INTERIOR BULKHEADS OPEN
1.48 257003 GENERAL VISUAL INSPECTION COMPARTMENT DOORS OPEN
1.49 257004 GENERAL VISUAL INSPECTION SEATS ANDTABLES OPEN
1.50 257005 GENERAL VISUAL INSPECTION CLOSET AND CABINETS OPEN
1.51 257006 GENERAL VISUAL INSPECTION CLOSET AND CABINET DOORS OPEN
1.52 257007 GENERAL VISUAL INSPECTION BED AND DIVANS OPEN
1.53 257011 CHECK SAFETY BELTS OPEN
1.54 352002 GENERAL VISUAL INSPECTION CHEMICAL 02 MASK OPEN
1.55 381120 CHECK WATER/WASTE DRAIN LINES OPEN
1.56 385010 CLEAN WATER/WASTE INSIDE FILTER OPEN
1.57 57-950-01 EXTERNAL ZONAL INSPECTION OF THE LEFT WINGLET OPEN
1.58 57-952-01 INTERNAL ZONAL INSPECTION LEFT WINGLET OPEN
1.59 57-960-02 EXTERNAL ZONAL INSPECTION OF THE RIGHT WINGLET OPEN
26-MAY-2015 © CAMP SYSTEMS 2 of 3
EFTA_R1_02140498
EFTA02714503
CAMP
A^....P•••••••••••ey
Work Order Contents Report
SERIAL : 29273 (YG006) REGNO : VP-BB) MODEL NAME : 88) 737.700IGW/-800/-900ER WORK ORDER At: VP-88) 2A CHECK 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.60 57-962-02 INTERNAL ZONAL INSPECTION OF THE RIGHT WINGLET OPEN
1.61 33-055-00 FUNCTIONAL CHECK THE EMERGENCY LIGHTING BATTERY PACKS FOR CAPACITY (15 MIN. MINIMUM) AND ONE OPEN
COMPLETE DEEP CYCLE.
1.62 72-020-01 DETAILED INSPECTION OF LEFT ENGINE INLET AND FAN BLADES. OPEN
1.63 72-020-02 DETAILED INSPECTION OF RIGHT ENGINE INLET AND FAN BLADES OPEN
Prepared By: Date:
Approved By: Date:
26-MAY-2015 © CAMP SYSTEMS 3 of 3
EFTA_R1_02140499
EFTA02714504
CAMP
A^....P••••••••••ey
Work Order Contents Report
SERIAL : 29273 (YG006) REGNO : VP-BEJ MODEL NAME : BB) 737.700IGW/-8001.900ER WORK ORDER At: VP-B8) DUE MX )UN. 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.0 737-28A1206 R3 FUEL - DISTRIBUTION - CENTER FUEL TANK BOOST PUMP AUTO SHUTOFF AND MASTER CAUTION LOGIC OPEN
CHANGE, SERVICE BULLETIN
2.0 252501 VISUALLY CHECK FORWARD ENTRY DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER OPEN
PRESSURE
3.0 252502 VISUALLY CHECK FORWARD SERVICE DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER OPEN
PRESSURE
4.0 252503 VISUALLY CHECK AFT ENTRY DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER PRESSURE OPEN
5.0 252504 VISUALLY CHECK AFT SERVICE DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER PRESSURE OPEN
6.0 FM 2005-18-23 CORROSION PROTECTION OF THE ELECTRICAL CONNECTORS IN THE MAIN WHEEL WELL OPEN
7.0 FM 2006-21-01 PART 1 FLIGHT CONTROLS AILERON AND AILERON TRIM CONTROL SYSTEM MEASURE THE FREEPLAY OF BOTH OPEN
AILERON CONTROL BALANCE TABS
8.0 FM 2006-21-01 PART 2 FLIGHT CONTROLS - AILERON AND AILERON TRIM CONTROL SYSTEM - REPETATIVE LUBRICATION OPEN
9.0 FM 2011.27-03 PAM (6)(1)(1)(1) DETAILED INSPECTION TO PREVENT AN UNDETECTED FAILURE OF THE PRIMARY LOAD PATH FOR THE OPEN
BALLSCREW IN THE DRIVE MECHANISM OF THE HSTA AND SUBSEQUENT WEAR AND FAILURE OF THE
SECONDARY LOAD PATH IN ACCORDANCE WITH SERVICE BUITIN 737-27A1277 R2
10.0 29-230-03 OPERATIONAL CHECK STANDBY RUDDER SYSTEM TO INCLUDE OBSERVING LOW PRESSURE LIGHT OPEN
ILLUMINATION AND THEN EXTINGUISHING.
11.0 24-120-00 (001.1) RESTORE MAIN BATTERY OPEN
12.0 24-120-00(002.1) RESTORE AUXILIARY BATTERY OPEN
13.0 254206 LAERDAL HEARTSTART FR DEFIBRILLATOR PADS OPEN
14.0 081001 WEIGHT CHECK OF AIRCRAFT OPEN
15.0 252901 CAPTAIN LIFE JACKET OPEN
16.0 252902 FIRST OFFICER LIFE JACKET OPEN
17.0 252903 FIRST OBSERVER LIFE JACKET OPEN
18.0 252904 NO. 1 FORWARD FLIGHT ATTENDANT LIFE JACKET OPEN
19.0 252905 NO. 2 FORWARD FLIGHT ATTENDANT LIFE JACKET OPEN
20.0 252906 NO. 1 AFT FLIGHT ATTENDANT UFE JACKET OPEN
21.0 252907 NO. 2 AFT FLIGHT ATTENDANT LIFE JACKET OPEN
22.0 252909 SECOND OBSERVER LIFE JACKET OPEN
23.0 256323 (001.1) OPERATIONAL CHECK OF THE NO. 1 FORWARD EMERGENCY FLASHUGHT OPEN
24.0 256323 (002,1) OPERATIONAL CHECK OF THE NO. 2 FORWARD EMERGENCY FLASHUGHT OPEN
25.0 256323 (003.1) OPERATIONAL CHECK OF THE NO. 1 COCKPIT FLASHLIGHT OPEN
26.0 256323 (004.1) OPERATIONAL CHECK OF THE NO. 2 COCKPIT FLASHUGHT OPEN
27.0 256323 (005.1) OPERATIONAL CHECK OF THE NO. 1 AFT EMERGENCY FLASHUGHT OPEN
28.0 256325 (003.1) OPERATIONAL CHECK OF THE CARGO NET OPEN
29.0 347105 (1) BIANNUAL CHECK EGPWS TERRAIN DATABASE VERSION STATUS OPEN
30.0 33.06600 RESTORE EMERGENCY LIGHTING BATTERY PACK (TWO OR MORE COMPLETE DEEP CYCLES) BATTERY CAPACITY OPEN
TO REQUIRED STANDARD
31.0 25-310-00 (002.1) RESTORE NO. 2 LIFE RAFT PRESSURE BOTTLE OPEN
32.0 25-420-03 (001.1) RESTORE FORWARD FIRST AID KIT OPEN
33.0 25-420-00 (002.1) RESTORE AFT FIRST AID KIT OPEN
34.0 25-430-00 (001.1) RESTORE MEDAIRE - BLUE FIRST AID MEDICAL KIT OPEN
26-MAY-2015 © CAMP SYSTEMS 1 of 2
EFTA_R1_02140500
EFTA02714505
CAMP
A^....P••••der...4 .•
Work Order Contents Report
SERIAL : 29273 (YG006) REGNO : VP-BB) MODEL NAME : 88) 737.700IGW/-800/-900ER WORK ORDER At: VP-B8.1 DUE MX )UN. 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
35.0 38-040-00 RESTORE WASTE DRAIN BALL VALVE THE WASTE DRAIN BALL-VALVE BY REPLACING SEALS (2) (OFF OPEN
AIRCRAFT)
36.0 FM 2015-04-02 NO. 1ENGINE - ENGINE FUEL AND CONTROL - MODIFY THE ENGINE BY REMOVING FULL AUTHORITY DIGITAL OPEN
ENGINE CONTROL (FADEC) SOFTWARE, VERSION 7.B.V4 OR EARUER, INSTALLED IN THE ELECTRONIC ENGINE
CONTROL (EEC)
37.0 FM 2015-04-02 NO. 2 ENGINE - ENGINE FUEL AND CONTROL - MODIFY THE ENGINE BY REMOVING FULL AUTHORITY DIGITAL OPEN
ENGINE CONTROL (FADEC) SOFTWARE, VERSION 7.B.V4 OR EARLIER, INSTALLED IN THE ELECTRONIC ENGINE
CONTROL (EEC)
38.0 25-300-00 (002.1) INSPECT AFT LIFE RAFT OPEN
39.0 25-300-00 (003.1) INSPECT NO. 3 LIFE RAFT OPEN
40.0 26-330-00 (002.1) REPLACE (LIID2) CARGO FIRE EXTINGUISHER BOTTLE AFT SQUIB OPEN
41.0 25-60-00 GENERAL VISUAL INSPECTION OF ALL COCKPIT / CABIN EMERGENCY EQUIPMENT OPEN
42.0 28-054-00 OPERATIONAL CHECK (BITE) THE FUEL PUMP GFI RELAY OPEN
43.0 28-056-00 FUNCTIONALLY CHECK THE CENTER TANK FUEL BOOST PUMP POWER FAILED ON PROTECTION SYSTEM OPEN
44.0 28-115-00 FUNCTIONALLY CHECK THE CENTER TANK BOOST PUMP AUTO SHUTOFF SYSTEM OPEN
45.0 28-AWL-19 REVIEW CENTER TANK FUEL BOOST PUMP AUTOMATIC SHUTOFF SYSTEM OPEN
46.0 28-AWL-20 REVIEW OVER-CURRENT AND ARCING PROTECTION ELECTRICAL DESIGN FEATURES OPERATION - BOOST PUMP OPEN
GROUND FAULT INTERRUPTER (CFI)
47.0 28-AWL-23 FUNCTIONALLY TEST CENTER TANK FUEL BOOST PUMP POWER FAILED ON PROTECTION SYSTEM. OPEN
48.0 737015 (I) ANNUAL CHECK OF EEC# I & EEC#2 SOFTWARE ENGINE FUEL AND CONTROL ECU SOFTWARE STATUS OPEN
49.0 FM 2011.27-03 PAM (G)(1XI)(2) LUBRICATE TO PREVENT AN UNDETECTED FAILURE OF THE PRIMARY LOAD PATH FOR THE 8A11FrREW IN THE OPEN
DRIVE MECHANISM OF THE HSTA AND SUBSEQUENT WEAR AND FAILURE OF THE SECONDARY LOAD PATH IN
ACCORDANCE SERVICE BULLETIN 737-27A1277 R2
50.0 347101 UPDATE NAV DATABASE OPEN
Prepared By: Date:
Approved By: Date:
26-MAY-2015 © CAMP SYSTEMS 2 of 2
EFTA_R1_02140501
EFTA02714506
DataSet-10
Unknown
1 pages
To:
Cc: Larry Visoski
Fm: Greg Wyler
Sent Tue 4/8/2014 2:13:38 PM
Subject Re: Jeffrey Epstein
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, wrote:
Hello Greg...Jeffrey says you would like a ride tonight on his plane to St. Thomas...He also has ki
ndly 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 y
our schedule....
Wheels up from Teterboro tonight is 6pm...Did you and Jeffrey discuss riding together to Teterbo
ro?...please let me know any details...
We will need your full name as it appears on your ID please for our flight log/pilot.
ank
Th you,
M t to Jeffrey Epstein
EFTA_R1_00728219
EFTA02109158
DataSet-11
Unknown
154 pages
180
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and PAUL G.
CASSELL„
Plaintiffs,
vs.
ALAN M. DERSHOWITZ,
Defendant.
CONTINUED VIDEOTAPE DEPOSITION OF
ALAN M. DERSHOWITZ
VOLUME 2
Pages 180 through 333
Friday, October 16, 2015
9:18 a.m. - 12:26 p.m.
Cole Scott & Kissane
110 Southeast 6th Street
Fort Lauderdale, Florida
Stenographically Reported By:
Kimberly Fontalvo, RPR, CLR
Realtime Systems Administrator
www.phi sre orting.com
EFTA02726484
181
1 APPEARANCES:
2
On behalf of Plaintiffs:
3
SEARCY, DENNEY, SCAROLA
4 BARNHART & SHIPLEY, P.A.
2139 Palm Beach Lakes Boulevard
5 West Palm Beach, Florida 33402-3626
BY: JACK SCAROLA, ESQ.
6
7
8 On behalf of Defendant:
9 COLE, SCOTT & KISSANE, P.A.
Dadeland Centre II - Suite 1400
10 9150 South Dadeland Boulevard
Miami, Florida 33156
11 BY: THOMAS EMERSON SCOTT, JR., ESQ.
12 BY: ST ISAFRAG. (Via phone)
13 --and--
14 SWEDER & ROSS, LLP
131 Oliver Street
15 Boston, MA 02110
BY: KENNETH A. SWEDER, ESQ.
16 •
17 --and--
18 WILEY, REIN
17769 K Street NW
19 Washington, DC 20006
BY: RICHARD A. SIMPSON, ESQ.
20
BY: NICOLE A. RICHARDSON, ESQ.
21
22
23
24
25
www.piiiiiiiiiiiiir.com
EFTA02726485
182
1 APPEARANCES (Continued):
2 On behalf of Jeffrey Epstein:
3 DARREN K. INDYKE, PLLC
575 Lexington Ave., 4th Fl.
4 New York, New York
BY: DARREN K. INDYKE, ESQ. (Via phone)
5
6 On behalf of
7 BOIES, SCHILLER & FLEXNER, LLP
401 E. Las Olas Blvd., Ste. 1200
8 Fort Lauderdale Florida 33301
BY:
9
10
11 ALSO PRESENT:
12 Joni Jones, Utah Attorney General Office
13 Travis Gallagher, Videographer
14
15
16
17
18
19
20
21
22
23
24
25
www.phi sre orting.com
EFTA02726486
183
1 INDEX
2
Examination Page
3
4 VOLUME 2 (Pages 180 - 333)
5 Direct By Mr. Scarola 184
6 Certificate of Oath 330
Certificate of Reporter 331
7 Read and Sign Letter to Witness 332
Errata Sheet (forwarded upon execution) 333
8 PLAINTIFF EXHIBITS
9
No. Page
10
1 Television Interview Transcript 193
11
2 Except from Deposition of Alan M. 193
12 Dershowitz
13 3 Photograph - 8x10 - Color 194
14 4 Photograph - 8x10 - Color 197
15 5 Flight Log Information Sheet 198
16 6 Composite - Flight logs 240
17 7 Composite - Flight manuals 240
18 8 Photograph - 8x10 - Color 305
19 9 Composite - Calendar entries 306
20 10 Composite - Calendar entries 307
21 11 Composite - Calendar entries 307
22 12 Composite - Calendar entries 307
23
24
25
www.phi sre orting.com
EFTA02726487
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1 VIDEOGRAPHER: Going on the record. This
2 is day two of Alan Dershowitz's deposition.
3 The date is October 16, 2015, and the time is
4 approximately 9:18 a.m.
5 MR. SCAROLA: Would you please reswear the
6 witness.
7 THE COURT REPORTER: Would you raise your
8 right hand, please?
9 Do you swear or affirm that the testimony
10 you are about to give will be the truth, the
11 whole truth, and nothing but the truth?
12 THE WITNESS: Yes.
13 Thereupon:
14 ALAN M. DERSHOWITZ
15 having been first duly sworn, was examined and
16 testified as follows:
17 DIRECT EXAMINATION
18 BY MR. SCAROLA:
19 Q. Mr. Dershowitz, what is rhetorical
20 hyperbole?
21 A. Rhetorical means verbal and hyperbole
22 means exaggeration.
23 Q. Something other than the truth, correct?
24 A. Truth --
25 MR. SCOTT: Objection, form, relevancy.
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1 A. Truth has many, many meanings and is a
2 continuum. The Supreme Court has held that
3 rhetorical hyperbole cannot be the basis, for
4 example, of perjury prosecutions or generally of a
5 defamation prosecution.
6 So it depends on the context. You might
7 just look at the dictionary and probably get a
8 variety of definitions for it.
9 BY MR. SCAROLA:
10 Q. Well, what I'm concerned about,
11 Mr. Dershowitz, is not a dictionary definition. I
12 want to know what your understanding of rhetorical
13 hyperbole is.
14 And do you agree that pursuant to your
15 understanding of rhetorical hyperbole, it is an
16 exaggeration beyond the facts?
17 MR. SCOTT: Objection, argumentative and
18 compound, three questions.
19 A. No --
20 MR. SCOTT: You can answer.
21 A. -- I would not agree with that definition.
22 BY MR. SCAROLA:
23 Q. Okay. Then define it for us, if you
24 would, please.
25 A. I think I have already.
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1 Q. I'm sorry, I missed the definition. Could
2 you tell us what rhetorical hyperbole is?
3 MR. SCOTT: Objection, repetitious. He's
4 done it.
5 A. Why don't we just read back my answer.
6 BY MR. SCAROLA:
7 Q. Because I didn't understand it, so I would
8 like you to try to give us a direct response to that
9 question if you're able to.
10 A. I will repeat exactly what I said. A
11 rhetorical means verbal and hyperbole means some
12 exaggeration of the facts for political or other
13 reasons, but generally it is truthful in a literal
14 sense but perhaps -- it all depends on context.
15 And if you tell me the context in which I
16 used it, I will be happy to describe what I meant in
17 that context. But I don't think you can really
18 answer a question about what two words put together
19 mean without understanding the context.
20 Q. Okay. Well, we're going to talk about
21 some context.
22 Do you recall having been interviewed on
23 on
24 A. I have no current recollection of --
25 MR. SCOTT: Do you have a copy of the
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1 transcript of the interview? We'd like to see
2 it.
3 MR. SCAROLA: That's exactly what I gave
4 you, the photocopy.
5 MR. SCOTT: We're doing it right now.
6 Maybe we can move on and come back then.
7 MR. SCAROLA: No, I would like to proceed.
8 MR. SCOTT: Then let's stop until I get a
9 copy of it. Because he -- I want --
10 MR. SCAROLA: I don't think that's
11 necessary because your client has told us that
12 he has a superb memory and one of the things I
13 would like to know is what he's able to recall.
14 If he needs to refresh his memory, the
15 transcripts will be here in just a moment, but
16 I don't want to delay going forward.
17 MR. SCOTT: Do you need the transcript to
18 refresh your memory?
19 THE WITNESS: Well, I have no memory of
20 what specifically I said on a particular day in
21 a particular interview.
22 MR. SCOTT: Since you have a copy in front
23 of him, why don't you just show him your copy
24 then? Read the -- ask your question and let
25 him read it.
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1 BY MR. SCAROLA:
2 Q. Do you recall having been interviewed on
3 by
4 A. Yes, I do.
5 Q. Do you recall having been interviewed on
6 by in early
7 where you spoke about matters that have become the
8 subject of this litigation?
9 A. Yes, I do.
10 Q. Did you make the following statement
11 during the course of that interview: "As to the
12 airplanes, there are manifests that will prove
13 beyond any doubt that I was never on a private
14 airplane with this woman or any other underage
15 girl"?
16 MR. SCOTT: You need to see the
17 transcript?
18 THE WITNESS: No. No.
19 A. That is a truthful statement. I would
20 repeat it right now. I've reviewed the manifests.
21 First, I know I was never on the airplane
22 with any underage woman. I know that for a fact. I
23 have absolutely no doubt in my mind about that. And
24 the records that I have reviewed confirm that.
25 They have on a number of
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1 airplane flights with Jeffrey Epstein. They have me
2 on a number of flights, none -- let me emphasize,
3 none within the relevant time period, none within
4 the relevant time period. That is, there are no
5 manifests that have me on Jeffrey Epstein's airplane
6 during the time that claims to
7 have -- falsely claims to have had sex with me.
8 So, yes, not only recall making that
9 statement, but I repeat it here today. And it is
10 absolutely true. And it just confirms what I know,
11 and that is that made up the entire
12 story.
13 BY MR. SCAROLA:
14 Q. Your statement --
15 MR. SCOTT: What page are you reading
16 from?
17 MR. SCAROLA: Page 5.
18 Q. Your statement was that you were never on
19 a private airplane with this woman, which I assume
20 was a reference to , correct?
21 A. It is, yes.
22 Q. Or any other underage girl?
23 A. That's right.
24 Q. All right. How many times --
25 A. Well, let me be very clear. I have no
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1 idea who was in the front cabin of the airplane with
2 the pilots. Obviously what I intended to say and
3 what I say here now is I never saw an underaged
4 person on an airplane.
5 Now, when I -- when I flew with Jeffrey
6 Epstein to the launch, my recollection is that there
7 may have been a couple on the plane with their child
8 who was going to see the launch. But that was
9 certainly not the context in which I made the
10 statement.
11 I never saw any underage, young person who
12 would be the subject or object of any improper
13 sexual activities. Had I seen Jeffrey Epstein ever
14 in the presence of an underage woman in a context
15 that suggested sexuality, I would have, A, left the
16 scene; B, reported it; and, C, never had any further
17 contact with Jeffrey Epstein.
18 Q. You have also made the statement that you
19 were never on a private airplane with any underage
20 women or any young women, correct?
21 A. The context was underage women in a sexual
22 context. If it was a -- you know, a four-year-old
23 child being carried by her mother, that would not be
24 included in what I intended to say.
25 Q. Your sworn testimony yesterday, according
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1 to the transcription, the official transcription of
2 that testimony, was that, quote:
3 "Let me emphasize that the manifests that
4 do exculpate me do not show me flying with
, they do not show me flying with any young
6 women."
7 That was the testimony you gave under
8 oath. Do you stand by that testimony today?
9 A. The manifests that I saw corroborate my
10 own memory -- my own memory is as clear as could
11 be -- that I never saw any inappropriately aged,
12 underaged women on any airplane to my knowledge that
13 were visible to me at any time that I flew. That is
14 my testimony, yes.
15 Q. Well, that's not a response to the
16 question that I asked. Is it your testimony today
17 that you never flew on a private airplane with,
18 quote, "any young women"?
19 MR. SCOTT: Objection, form.
20 A. By young women, I obviously meant in that
21 context underage women. And underage women in the
22 context of sexuality. And, yes, I I stand by
23 that statement.
24 BY MR. SCAROLA:
25 Q. All right. So your your clarification
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1 of your earlier testimony is that you never saw any
2 young women in a sexual context?
3 A. That's not clarification. I think that's
4 what I initially said. That's what I initially
5 intended. And that's the way any reasonable -- any
6 reasonable person would interpret what my original
7 testimony was. So I don't believe my original
8 testimony required any clarification.
9 Q. So what you meant to convey by the
10 statement that you made when you said you never flew
11 with any underage girl or any young women was you
12 never flew with any underage girl or young women in
13 a sexual context?
14 MR. SCOTT: Objection, form.
15 BY MR. SCAROLA:
16 Q. Is that correct?
17 A. Let me simply repeat the fact and that is,
18 to my knowledge, I never flew on an airplane or was
19 ever in the presence on an airplane with any
20 underage woman who would be somebody who might be in
21 a sexual context. I say that only to eliminate the
22 possibility that some four-year-old was on the lap
23 of a mother or somebody was on the airplane with
24 family members.
25 But, no, I do not recall -- and I'm very
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1 firm about this -- being on an airplane with anybody
2 who I believed could be the subject of Jeffrey
3 Epstein or anyone else's improper sexual activities.
4 MR. SCAROLA: All right. Let's mark the
5 transcript that we've been referring to as
6 Exhibit Number 1, please. That's the
7 transcript of the television interviews that
8 we'll be discussing.
9 (Thereupon, marked as Plaintiff Exhibit
10 1.)
11 MR. SCOTT: This is actually 2, right? We
12 had one yesterday, an article from the British
13 newspaper?
14 MR. SCAROLA: No. It was not marked as an
15 exhibit. This is the first exhibit that's been
16 marked.
17 MR. SCOTT: No, I know that, but I thought
18 we were going to mark that one. Maybe I was --
19 I asked for that. Okay.
20 It was an answer and counterclaim about
21 the allegation shown to the witness.
22 MR. SCAROLA: And Exhibit Number 2 will be
23 the transcript from yesterday's proceedings
24 that I have just referenced.
25 (Thereupon, marked as Plaintiff
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1 Exhibit 2.)
2 MR. SCOTT: You don't have a copy of that,
3 do you, of the transcript?
4 MR. SCAROLA: No. Got sent to you. I
5 assume you have it.
6 BY MR. SCAROLA:
7 Q. I'm going to hand you what we'll now mark
8 as Exhibit Number 3.
9 (Thereupon, marked as Plaintiff
10 Exhibit 3.)
11 MR. SCOTT: There's no question.
12 MR. SWEDER: Yes.
13 BY MR. SCAROLA:
14 Q. Do you recognize that young woman,
15 Mr. Dershowitz?
16 A. No.
17 Q. Never saw her?
18 A. Not that I know of.
19 Q. Never flew on an private airplane with
20 her?
21 A. Not that I know of.
22 Q. Do you recognize the name
23 A. I do recall that Jeffrey Epstein had a
24 friend named
25 Q. That you flew with?
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1 A. I don't remember that I flew with her or
2 not. I may have. But I don't recall necessarily.
3 But I did meet I remember meeting a woman named
4 . This does not look like , like the
5 woman I met.
6 Q. Okay. So that's a -- that's a different
7
8 A. No, I don't know.
9 MR. SCOTT: Objection, form,
10 argumentative.
11 A. I have no idea. I do not recognize this
12 woman. She's not familiar to me at all.
13 I can tell you this: Without any doubt, I
14 never met anybody dressed like this on any airplane
15 or in the presence of Jeffrey Epstein or in any
16 context --
17 BY MR. SCAROLA:
18 Q. Did she have
19 A. -- related to this case.
20 Q. -- more clothes on or less clothes on when
21 you met her?
22 MR. SCOTT: Objection, form. He said he
23 never met her. Misrepresent --
24 BY MR. SCAROLA:
25 Q. When you met the woman that you're
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1 referencing, did she have more clothes on or less
2 clothes on than that woman?
3 A. Every woman that I met in the presence of
4 Jeffrey Epstein was properly dressed, usually in
5 suits and dresses and -- and appropriately covered
6 up. I never met any women in the context of Jeffrey
7 Epstein who were dressed anything like this.
8 Q. Would you agree that that is a young woman
9 in that photograph?
10 A. I have no idea what her age is.
11 Q. So you don't know whether she was underage
12 or overage or a young woman or not a young woman?
13 A. I don't --
14 MR. SCOTT: Objection, form.
15 A. -- know this woman, so I have no idea how
16 old a woman in a picture is. She could be -- she
17 could be 30. She could be 25. I have no idea.
18 BY MR. SCAROLA:
19 Q. Or she could be 15 or 16?
20 A. I don't think so.
21 Q. But you don't know?
22 A. This doesn't -- well, I don't know how old
23 you are. This does not strike me
24 Q. Old enough to know that
25 MR. SCOTT: You're cutting --
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1 BY MR. SCAROLA:
2 Q. -- that's a young woman.
3 MR. SCOTT: Objection. You're cutting the
4 witness off. You're not letting him finish.
5 A. This looks like a picture out of a Playboy
6 or Penthouse magazine. It does not look to me like
7 a person who is under the age of 16 or 17 or 18.
8 But I don't think you can tell anything from the
9 picture. I think you can tell much more from
10 meeting somebody and being with them and having a
11 conversation with them.
12 MR. SCAROLA: Let's mark this photograph,
13 if we could, as Exhibit Number 4.
14 (Thereupon, marked as Plaintiff
15 Exhibit 4.)
16 BY MR. SCAROLA:
17 Q. Does Exhibit Number 4 help you at all to
18 recognize this young woman?
19 A. I've never -- I have no -- no recollection
20 of this young woman at all.
21 Q. All right. Would you describe for us,
22 please, the that you flew with Jeffrey
23 Epstein on November 17, 2005?
24 A. First, I want to emphasize that that's
25 three years later than any of the issues involved in
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1 this case. I have no recollection of flying with
2 this woman. I saw the name on a manifest.
3 And my recollection of -- I have
4 no recollection of flying with her, but my
5 recollection of is that she was a serious,
6 mid 20s woman friend of Jeffrey Epstein, who I may
7 have met on one or two or three occasions when he
8 was with her in -- perhaps at Harvard University
9 where he was meeting with academics and scholars, or
10 perhaps -- I think that's probably the context
11 where -- where she might have been.
12 Q. But you never flew with her?
13 A. I have no recollection of flying with her.
14 Q. Okay. Well, let me see if this helps to
15 refresh your recollection, Mr. Dershowitz.
16 MR. SCAROLA: Let's mark this as Exhibit
17 Number 5, please.
18 THE WITNESS: Uh-huh, yes.
19 (Thereupon, marked as Plaintiff
20 Exhibit 5.)
21 BY MR. SCAROLA:
22 Q. Do you see that the name of the woman in
23 the photographs I have handed you is
24 a model?
25 The photographs, sir, look at the
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1 photographs. The photographs identify the woman as
2 , correct?
3 A. Yes, but --
4 MR. SCOTT: Mr. Dershowitz, take your
5 time --
6 THE WITNESS: Yeah.
7 MR. SCOTT: -- review the exhibits. Don't
8 be rushed by Mr. Scarola.
9 A. Yes, it's a different different
10 spelling of the name. The on the manifest
11 is spelled
12 The in the photograph is
13 . I have no idea whether --
14 BY MR. SCAROLA:
15 Q. The last name --
16 A. they are the same person.
17 Q. is the same, , right?
18 A. There's no last name.
19 Q. Well, read down a little bit further, if
20 you would, Mr. Dershowitz.
21 A. You mean as to a different flight?
22 Q. Yes, sir. Identifying the return flight
23 for the same
24 A. I have no idea that it's a return flight.
25 I have nothing on the record that suggests that it's
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1 a return flight. And it has different people on it.
2 So I have no reason to believe it's a return flight.
3 Q. Is the last -- the question that I asked
4 you, Mr. Dershowitz, is: Is the last name spelled
5 exactly the same as the last name is spelled in the
6 two photographs I have shown you?
7 A. Let me look. So, on the 20th of
8 November
9 Q. Is the last name --
10 MR. SCOTT: Whoa, whoa
11 BY MR. SCAROLA:
12 Q. -- spelled the same way on both the flight
13 log and the two photographs I have shown you?
14 A. On -- you mean on a flight log that I was
15 not on the flight? Is that right? You're talking
16 about a flight log that I was not on the flight,
17 right?
18 Q. That flight log shows you on multiple
19 flights, does it not?
20 A. It shows me not on that flight. It shows
21 me on a number of flights, but not on that flight.
22 MR. SCOTT: What's the date of the
23 flights?
24 THE WITNESS: The date of that flight
25 is -- looks like November 20th, 2005, more
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1 than three years after left
2 for --
3 BY MR. SCAROLA:
4 Q. Mr. Dershowitz --
5 MR. SCOTT: You're cutting the witness
6 off.
7 MR. SCAROLA: He's not answering my
8 question, Tom.
9 MR. SCOTT: Well --
10 MR. SCAROLA: I want to know whether the
11 last name is spelled the same or it isn't
12 spelled the same on the flight log marked as an
13 exhibit and on the photographs. That's a very
14 direct question. It calls for a very direct
15 yes or no response.
16 And this witness has demonstrated a clear
17 refusal to respond directly to direct
18 questions, which will result, when we resume
19 this deposition, in our requesting that the
20 Court appoint a special master so that this
21 deposition doesn't take two weeks to complete.
22 MR. SCOTT: You know, Mr. Scarola, that's
23 a nice speech and I appreciate it.
24 MR. SCAROLA: Thank you.
25 MR. SCOTT: I don't agree with your
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1 characterization. And if you recall, months
2 ago I suggested a special master for this
3 deposition, for your clients' depositions and
4 for ' and your response to me
5 was: I'll consider it, I won't pay for it. If
6 your client wants to pay for it -- so basically
7 you blew me off.
8 So, I appreciate you finally come around.
9 And your clients.
10 MR. SCAROLA: Your client's misconduct has
11 clearly convinced me, having now considered it,
12 that it is absolutely necessary.
13 MR. SCOTT: Okay. Now --
14 BY MR. SCAROLA:
15 Q. So now could I get an answer to my
16 question --
17 MR. SCOTT: Now that we have --
18 BY MR. SCAROLA:
19 Q. -- whether the last name on the flight log
20 is spelled exactly the same way as the last name in
21 the photographs?
22 MR. SCOTT: Now that all the lawyers'
23 speeches are done, read the question back and
24 the witness will answer it.
25 MR. SCAROLA: I will repeat the question.
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1 BY MR. SCAROLA:
2 Q. Is the last name on the photograph spelled
3 exactly the same way as the last name on the flight
4 log?
5 A. If you're talking about a flight log that
6 I was not on that flight, the answer is yes.
7 Q. All right. Thank you very much, sir.
8 Now, that flight log also shows you flying
9 repeatedly in the company of a woman named
10 correct?
11 A. I've only seen one reference to on
12 November 17. If you want to show me any other
13 references, I'd be happy to look at them.
14 Q. All right, sir. Thank you.
15 Let's go back to the --
16 MR. SCOTT: Are we done with this exhibit?
17 MR. SCAROLA: We are done with the
18 exhibit.
19 MR. SCOTT: Okay. Then let's collect the
20 exhibits so that we don't have a big -- then
21 we'll turn them over to the court reporter to
22 keep safekeeping.
23 There you go, young lady, don't lose
24 those, don't get them wet. And we'll proceed.
25
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1 BY MR. SCAROLA:
2 Q. Did you state during the same interview,
3 the ■ interview: "She has said that
4 Bill Clinton was with her at an orgy on Jeffrey's
5 island"?
6 A. I did state that, yes.
7 Q. Was that statement intended as fact,
8 opinion, or was it intended as rhetorical hyperbole?
9 MR. SCOTT: Do you understand the
10 question?
11 THE WITNESS: Yes, I do.
12 A. It was a statement based on what I
13 believed were the facts at the time I said them.
14 Various newspapers and blogs had placed
15 Bill Clinton on, quote, "orgy island" on -- in the
16 presence of Jeffrey Epstein when there were orgies.
17 And at the time I made that statement, I had a
18 belief that she had accused Bill Clinton of
19 participating or being -- as being a part of or an
20 observer or -- or a witness or a participant in
21 orgies on what was called Jeffrey Epstein's orgy
22 island. That was my state of belief, honest belief
23 at the time I made that statement.
24 BY MR. SCAROLA:
25 Q. Yes, sir. And what I want to know is what
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1 the source of that honest belief was? Identify any
2 source that attributed to the
3 statement that Bill Clinton was with her at an orgy
4 on Jeffrey's island.
5 A. We can provide you about, I think, 20
6 newspaper articles and blogs which certainly raise
7 the implication that Bill Clinton had improperly
8 participated in sexual activities on the island
9 either as an observer or as a participant. The
10 issue was raised on Sean Hannity's program. The
11 headlines in various British media had suggested
12 that.
13 It's my belief that
14 intended to convey that impression when she was
15 trying to sell her story to various media, which she
16 successfully sold her story to in Britain, that she
17 wanted to keep that open as a possibility.
18 And then when I firmly declared, based on
19 my research, that Bill Clinton had almost certainly
20 never been on that island, she then made a firm
21 statement that she -- which was a -- which was a
22 perjurious statement, a firm perjurious statement
23 saying that although Bill Clinton had been with her
24 on the island and had had dinner with her, the
25 perjurious statement was that Bill Clinton had been
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1 on the island with her.
2 The lie was that she described in great
3 detail a dinner with Bill Clinton and two underaged
4 Russian women who were offered to Bill Clinton for
5 sex but that Bill Clinton turned down.
6 So she then put in her affidavit that
7 although -- perjuriously, although she had seen Bill
8 Clinton on that island, she then stated that she had
9 not had sex with Bill Clinton. To my knowledge,
10 that was -- to my knowledge at least, that was the
11 first time she stated that -- that she not had sex
12 with Bill Clinton. She had certainly implied, or at
13 least some of the media had inferred from her
14 statements that she may very well have observed Bill
15 Clinton in a sexually compromising position.
16 So, when I made that statement to Don
17 Lemon, I had a firm belief, based on reading
18 newspaper accounts and blogs, that it was true.
19 Q. Can you identify a single newspaper that
20 attributed to the statement that
21 Bill Clinton was with her at an orgy on Jeffrey's
22 island?
23 A. I think there -- I don't have them in my
24 head right now. But I do recall reading headlines
25 that talked about things like, sex slave places
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1 Clinton on orgy island, things of that kind. I
2 would be happy to provide them for you. I don't
3 have them on the top of my head.
4 Q. There's a big difference between saying
5 that Bill Clinton was on Jeffrey's island and saying
6 that Bill Clinton was at an orgy on Jeffrey's
7 island, isn't there?
8 MR. SCOTT: Objection --
9 BY MR. SCAROLA:
10 Q. Do you recognize a distinction between
11 those statements?
12 MR. SCOTT: Form.
13 A. I don't think that distinction was clearly
14 drawn by the media.
15 BY MR. SCAROLA:
16 Q. I'm asking whether you recognize the
17 distinction?
18 A. Oh, I -- I certainly recognize a
19 distinction.
20 Q. Oh, so
21 A. Let me finish. I certainly recognize a
22 distinction between Bill Clinton being on the
23 island, which I believe she perjuriously put in her
24 affidavit, and Bill Clinton participating actively
25 in an orgy. I also think it's a continuum.
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1 And there is the possibility, which I
2 don't personally believe to be true, that he was on
3 the island. There was the possibility, which I
4 don't believe to be true, that he was on the island
5 when orgies were taking place. There was the
6 possibility that he was on the island and observed
7 an orgy, and there was the possibility that he was
8 on the island and participated in an orgy.
9 Newspapers picked up those stories. I'll
10 give you an example of a newspaper that actually
11 said that that she had placed or that I was on the
12 island and -- that I participated in an orgy along
13 with Stephen Hawkings [sic.), the famous physicist
14 from Cambridge University, that was a newspaper
15 published in the Virgin Islands, which falsely
16 claimed that I was at an orgy with Stephen Hawkings.
17 So, many newspapers were suggesting,
18 implying, and I inferred from reading those
19 newspapers that that's what she had said to the
20 media.
21 If I was wrong about that based on
22 subsequent information, I apologize. But I
23 certainly, at the time I said it, believed it and
24 made the statement in good faith in the belief that
25 it was an honest statement.
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1 Q. Okay. So you now are withdrawing the
2 statement that you made that said
3 that Bill Clinton was with her at an orgy on
4 Jeffrey's island; that was wrong?
5 A. I don't know whether she ever said that.
6 I would not repeat that statement and have not
7 repeated that statement based on her denial. As
8 soon as she denied it, I never again made that
9 statement and would not again make that statement.
10 Q. You --
11 A. But I did reiterate the fact that she
12 committed perjury when she said she was on the
13 island with Bill Clinton.
14 MR. SCAROLA: Move to strike the
15 nonresponsive --
16 A. That was the perjurious statement.
17 MR. SCAROLA: Move to strike the
18 nonresponsive portions of the answer.
19 BY MR. SCAROLA:
20 Q. You have made a reference during that same
21 ■ interview to this woman, referring to
23 A. That's right.
24 Q. Okay. What -- what is a criminal record?
25 A. Well, the way I used the term is that
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1
2
3
4
5 . And it was my
6 information that there was a
7
8 Q. How old was she at the time this alleged
9 offense occurred?
10 A. I don't know.
11
12 . To my knowledge, I -- I recall a case
13 where a 14-year-old boy was sentenced as an adult
14 for --
15 MR. SCAROLA: Mr. Scott --
16 A. -- a serious --
17 MR. SCAROLA: -- did my question ask
18 anything about a 14-year-old boy?
19 A. You asked if
20 MR. SCAROLA: Do we really need to listen
21 to this?
22 MR. SCOTT: You're asking questions, my
23 client is providing his response.
24 MR. SCAROLA: No, your client is not
25 responding. Your client is filibustering.
www.phi sre orting.com
EFTA02726514
211
1 Your client is doing everything he can to avoid
2 giving direct answers to these questions.
3 I would appreciate it if you would take a
4 break, counsel your client that the speeches
5 are not helpful to anyone, and especially not
6 helpful to him.
7 MR. SCOTT: If you want to take a break,
8 I'll take a break and I will advise my client
9 whatever I feel is appropriate, not what you
10 instruct me to do.
11 MR. SCAROLA: Okay. Well, if you think it
12 might help at all in the progress of this
13 deposition, then I do want to take a break. If
14 you don't think taking a break would be
15 helpful, I don't want to take a break.
16 MR. SCOTT: Do you want to take a break or
17 not?
18 THE WITNESS: I'm going to leave it to
19 your judgment. I'm happy to proceed --
20 MR. SCOTT: Okay. I'll be glad to take a
21 break.
22 MR. SCAROLA: Thank you.
23 MR. SCOTT: I can't say --
24 MR. SCAROLA: Five minutes.
25 MR. SCOTT: -- it will help you or
www.phi sre orting.com
EFTA02726515
212
1 anything but --
2 MR. SCAROLA: I can understand that you
3 don't -- you don't have that control, but if
4 there's any reasonable --
5 MR. SCOTT: You know, Counsel
6 MR. SCAROLA: -- prospect that it might
7 help, let's give it a try.
8 MR. SCOTT: You know, I really don't
9 appreciate the comments about my abilities as
10 an attorney, like I don't have that control and
11 things of nature. It really is --
12 MR. SCAROLA: I don't have the control
13 either.
14 MR. SCOTT: It's not --
15 MR. SCAROLA: I'm not trying to disparage
16 you at all in any respect. I'm just suggesting
17 that --
18 MR. SCOTT: Okay.
19 MR. SCAROLA: -- there is reason to doubt
20 that it will do any good. But I want to give
21 it a try.
22 MR. SCOTT: Okay. Fine. Thank you.
23 MR. SCAROLA: Thank you.
24 VIDEOGRAPHER: Going off the record. The
25 time is approximately 9:49 a.m.
www.phi sre orting.com
EFTA02726516
213
1 (Recess was held from 9:49 a.m. until 10:01 a.m.)
2 VIDEOGRAPHER: Going back on the record.
3 The time is approximately 10:01 a.m.
4 MR. SCOTT: If you've finished your bagel,
5 we're ready to proceed, I think.
6 MR. SCAROLA: I think we are. I was
7 actually ready to proceed a little bit earlier,
8 but we'll proceed now.
9 BY MR. SCAROLA:
10 Q. Mr. Dershowitz, do you agree with the
11 basic concept that one is presumed to be innocent
12 until proven guilty?
13 A. Yes.
14 Q. Has
15 t any time, anywhere, at any
16 age?
17 A. I don't know the answer to that question,
18 but I do know that she was
19 and
20
21
22 Q. To the extent that anyone might interpret
23 your comment that was ever
24 , they would be drawing a false
25 conclusion as far as you know, correct?
www.phi sre orting.com
EFTA02726517
214
1 A. As far as I know, I don't know of her
2 having convicted of any crime. But I do know that
3
4 And I don't think she contested that. I don't think
5 there's any dispute about the fact that
6
7 Q. When did you find out about this alleged
8
9 A. As soon as the false allegation against me
10 was made public, I got call after call after call
11 from people telling me about , about
12 your 22 clients. The calls just kept coming in
13 because there was such outrage at this false
14 allegation being directed against me.
15 MR. SCAROLA: Move to strike the
16 unresponsive portion of the answer.
17 BY MR. SCAROLA:
18 Q. You found out as soon as the CVRA
19 complaint was -- the CVRA allegations referencing
20 you were filed; is that correct?
21 A. I didn't say that. I said as soon as they
22 were made public and as soon as the newspapers
23 carried these false stories, I received phone calls
24 and I learned about -- I learned about her encounter
25 with the criminal justice system.
www.phi sre orting.com
EFTA02726518
215
1 Q. That would certainly have been prior to
2 February 23rd of 2015, correct?
3 A. Yes.
4 MR. SCOTT: Are you going back to the
5 exhibit now with the newspapers and
6 MR. SCAROLA: Not yet.
7 MR. SCOTT: Okay.
8 BY MR. SCAROLA:
9 Q. Having reviewed the available airplane
10 flight logs, you are aware that Bill Clinton flew on
11 at least 15 occasions with Jeffrey Epstein on his
12 private plane, correct?
13 A. Yes.
14 Q. Have you ever attempted to get flight log
15 information with regard to Former President
16 Clinton's other private airplane travel?
17 A. No.
18 Q. Never made a public records request --
19 A. Yes.
20 Q. under the Freedom of Information Act
21 with regard to those records?
22 A. Well, we have made a Freedom of
23 Information request. My -- my attorney in New York,
24 Louis Freeh, the former head of the FBI, has made a
25 FOIA request for all information that would
www.phi sre orting.com
EFTA02726519
216
1 conclusively prove that Bill Clinton was never on
2 Jeffrey Epstein's island, yes.
3 Q. And you were denied those records,
4 correct?
5 A. No, no, no.
6 Q. Oh, you got them?
7 MR. SCOTT: Well, wait a minute. Let's
8 take it slow. Ask a question.
9 A. As any lawyer knows, FOIA requests take a
10 long, long period of time. So they were neither
11 denied nor were they given to us. They are very
12 much in process.
13 BY MR. SCAROLA:
14 Q. When was
15 A. While we're talking about may I
16 complete -- I want to amend one answer I gave
17 previously.
18 While we're talking about the plane logs,
19 I must say that during the recess, my wife Googled
20 and found out that she was, in fact, •
21 years old in_, at the time she flew on that
22 airplane. So that my characterization of her as
23 about ■ years old is absolutely correct.
24 And the implication that you sought to
25 draw by showing me those pictures was not only
www.phi sre orting.com
EFTA02726520
217
1 demonstrably false, but you could have easily
2 discovered that the implication you were drawing was
3 demonstrably false by simply taking one second and
4 Googling her name as my wife did.
5 BY MR. SCAROLA:
6 Q. And so at 25 years old, she wasn't a young
7 woman?
8 A. She was not the kind of woman that I was
9 describing as underage. She was a mature, serious,
10 I think I said in my public statements a model. I
11 wasn't aware at the time that see was working for
12 , but Google demonstrates that.
13 And I described her exactly, in exactly the right
14 terms, a serious person.
15 I always saw her dressed when I saw her --
16 I saw her maybe on two or three occasions, dressed
17 appropriately. She was a serious adult worker and I
18 think you insult and demean her when you suggest
19 that anything other
DataSet-9
Unknown
2 pages
From: "Greg Wyler"
To: Lesley Groff -MMIla>
Subject: Re: Jeffrey Epstein
Date: Wed, 09 Apr 2014 10:50:11 +0000
Thanks!
On Apr 9, 2014 6:49 AM, Lesley Groff wrote:
I hope you rec'd the answer earlier...it is:
On Apr 9, 2014, at 3:23 AM, "Greg Wyler" wrote:
> Is the WiFi available to uests here on the island? If so, what is the password? On Apr 8, 2014 2:19 PM, Lesle
y Groff wrote:
> tremendous. thanks
> On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote:
» My cell is
>> See you soon.
>> Original Message
>> From: Lesley Groff [mailto:
>> Sent: Tuesda Aril 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 7p
m 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:
>»
>»
EFTA00371346
>>> 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 b
e there around 4:15.
>>>
>>> I can drive strai ht 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 offer
ed you a ride in his helicopter over to Branson's island tomorrow...He did want to make sure you know he will n
eed 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
>>>
>>>
EFTA00371347
DataSet-9
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2 pages
Related Articles
New pictures show Stephen Hawking enjoying the hospitality of Jeffrey Epstein on the private Caribbean
island where Prince Andrew is alleged to have slept with an underage "sex slave".
The celebrated physicist can be seen at a barbecue on Little St James as well as taking a boat cruise and
submarine tour of the sea bed off the island.
Epstein, 61, is said to have paid for the submarine to be modified for Professor Hawking, who had never
been underwater before.
The Cambridge professor visited Epstein's "Island of Sin" in March 2006 shortly before the paedophile
billionaire was charged by police in Palm Beach with unlawful sexual activity with a minor.
Hawking was one of 21 internationally-renowned scientists attending a conference, funded by Epstein, on
gravity at the Ritz-Carlton hotel on neighbouring island St Thomas.
Epstein invited the scientists on trips to his 78-acre, private island retreat and was on hand to host them.
Brought in on the billionaire's private jets, nicknamed the Lolita Express by locals, numerous teenage
girls were allegedly made to take part in depraved orgies at his US Virgin Islands bolthole.
In court papers, alleges that her third and final sexual encounter with Prince Andrew
took place on the island when she was aged 17.
According to flight log books, the prince paid at least one visit aboard Epstein's private jet to the island,
although former staff claimed he frequented Little St James several times.
Buckingham Palace has strenuously denied that the Duke of York, a one-time friend of Epstein, ever had
sex with her.
On Linkedln, Epstein describes himself as a "science philanthropist".
His profile says: "Mr Epstein has contributed to many important scientific endeavours and conferences.
"His work has supported eminent scientists around the world, Nobel laureates and well-known luminaries
such as Stephen Hawking."
Stephen Hawking pictured on a sea bed tour on a submarine off Little St James (TIM STEWART NEWS LIMITED)
Besides Hawking, there were three Nobel laureates on the trips.
EFTA00716439
Among those pictured with Hawking on the boat cruise is Professor Lawrence Krauss, a theoretical
physicist who works at Arizona State University.
Legal documents have claimed that Epstein's properties were decorated with photographs of naked
adolescent girls, but Professor Krauss said that he saw nothing of the sort.
He said that the conference "wouldn't have happened if Epstein hadn't funded it" and that Epstein
continues to fund research and science education.
He said: "He's supporting some of the work at my institute."
He added that he would have had no idea about the court proceedings against Epstein if journalists had
not contacted him.
Epstein served 13 months of an i8-month jail sentence after pleading guilty to charges of soliciting a
minor.
He was allowed to spend much of his prison sentence working at his scientific institute, the Florida
Science Foundation.
In a strongly-worded statement, Buckingham Palace earlier said: "It is emphatically denied that the Duke
of York had any form of sexual contact or relationship with
"The allegations made are false and without any foundation."
A lawyer for Epstein has described the allegations of orgies by "sex slave" Roberts as "old and discredited".
EFTA00716440
DataSet-9
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2 pages
From: Christian Everdell
To: a" lYin>, " (USANYS)"
(USANYS)" <
Cc: "Mark S. Cohen" Bobbi Stcrnheim
Jeff Pagliuca , "'Laura Menninger"'
Subject: Discovery Requests
Date: Thu, 07 Jan 2021 21:13:14 +0000
Attachments: 2020.11.18_Maxwell_Discovery_Letter.pdf; 2006.12.06_FBI_Report.pdf; PROD011-
Ciaps.xlsx
Inline-Images: image005.jpg; image006.jpg
We write to raise a number of discovery issues. Please let us know your position on these issues at your earliest
convenience.
1. In our email correspondence on 11/18/2020, you agreed to create a new hard drive containing the entire discovery
production. We provided you with a 4TB hard drive for that purpose on 11/20/2020. It is very important for Ms.
Maxwell to have this drive as soon as possible to prepare her defense. Do you have an update on when the drive
will be ready?
2. We also informed you that the CD produced on November 18, 2020 did not work on the prison computer at the
MDC (as you know, the laptop provided to Ms. Maxwell does not have a CD drive). Accordingly, we asked you to
include the material on the CD in the new 4TB hard drive. We followed-up with you about this issue on December
30, 2020. Given that the new hard drive is still not ready, we ask that you download the material on the CD onto
a separate thumb drive or hard drive and provide it as quickly as possible to Ms. Maxwell at the MDC so that she
can review the materials this weekend. Alternatively, you can provide an external CD drive to Ms. Maxwell at the
MDC so that she can read the files on the MDC computer. We will provide whatever media device you require to
facilitate this production.
3. Unlike the November 9, 2020 discovery cover letter, the November 18, 2020 discovery cover letter (attached) does
not correlate the Bates numbers to the particular "Subject Device" from which the documents were recovered.
Instead, the cover letter indicates that the documents came from "SDNY_PROD015" or "SDNY_PROD016." We do
not know what those terms refer to. We request that the government produce a list that correlates the Bates
numbers for all of the documents in SDNY_PROD015 and SDNY_PROD016 to the particular devices from which the
documents were recovered.
4. We request that the government provide an unredacted version of the FBI report, dated December 6, 2006,
bearing Bates number SDNY_GM_02050812-14 (attached). We also request that the government produce a log
identifying all of the redacted documents in the discovery and the bases for each of the redactions.
5. There are a few documents that seem to be missing from the discovery. For example, the AT&T documents
(SDNY_GM_00001015-3637) do not seem to include subscriber information for the various phone numbers. Also,
the flight logs produced by David Rodgers begin at Bates number "Rodgers000028," suggesting that
Rodgers000001-000027 were not produced to us. Please produce these documents to us or provide an explanation
why you are not producing them to us. Please confirm whether there are other documents that were removed
from the grand jury subpoena productions that we have not yet identified and the basis for their removal.
6. There are a few Bates number/metadata issues with some of the documents:
a. There is an overlap between the fourth and fifth document productions. The fourth production ends at
SDNY_GM_00328863, the fifth production begins at SDNY_GM_00328070. We propose renumbering the
range from the fifth production (i.e., renumber SDNY_GM_00328070-328863).
b. The metadata load files (*.DAT) for PROD011 had a number of gaps which are detailed in the attached Excel
file. We propose that you send us a new DAT file covering only the missing documents.
c. The metadata load files (*.DAT) for PROD015 had a gap from SDNY_GM_00723971 to SDNY_GM_00723981.
We propose that you send us a new DAT file covering only the missing documents.
EFTA00080618
7. To the extent that the government has created an index of the documents produced on November 9 and
November 18 that is more detailed than the production cover letters, we request that you provide a copy to the
defense.
8. We request that the government provide copies of the grand jury subpoenas for documents issued by the
government in this case. Also, please identify the date range of documents you requested in each subpoena.
There is one other issue we'd like to raise. An article in the Daily Beast on Monday referenced the search warrant affidavit
for the cell-site simulator used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how-
the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared
in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in anything that was filed on the
court docket. Please confirm whether or not the government unsealed this affidavit or any other materials from the
criminal discovery, and whether any discovery materials were released pursuant to FOIA requests.
Regards,
Chris
Christian R Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
I
New York I Paris I Washington DC I London
CONFIDENTIAUTY NOTICE: The Information contained in this e-mail may be confidential and/or privileged. This e-moil is Intended lobe reviewed initially by only the Individual
named above. If the reader of this e-moil is not the Intendedrecipient or a representonVe of the intended incipient, you ore hereby notified that any reWew, dissemination or
copying of this e-mail or the information contained herein is prohibited. If youhove received this e-mail in error, please Immediately nodfy the sender by telephone and
permanently delete this e-mail. Thank you.
PRIVACY: A complete copy of our privacy policy con be viewed ot: https://www.cohenpressetcom/pnvact cE
EFTA00080619
DataSet-10
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1 pages
To:
Cc:
From: Larry Visoski
Sent: Tue 4/8/2014 2:36:24 PM
Subject: Re: Jeffrey Epstein
Great Greg,
Welcome aboard !
Look fwd to seeing you again,
All the best
Larry
Thx for the heads up.
Sent from my iPhone
> on Apr 8, 2014, at 10:13 AM, "Greg Wyler" fl 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 All, I > 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,
> Assistant to Jeffrey Epstein
EFTA_R1_00728345
EFTA02109236
DataSet-9
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23 pages
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23
PRIVILEGE LOQ
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 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
EFTA00065065
Case 9:08-cv-80736-KAM Document 212-1 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 a 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
EFTA00065066
Case 9:08-cv-80736-KAM Document 212-1 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 a handwritten notes, 302s, documents subject to
rtions 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 chart, witness/victim names and contact Contains information and
P-002769 list, attorney (=. handwritten notes, 302s, documents subject to
'lions of state investigative file, attorney investigative privilege. Also
yped 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
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 ( ) handwritten notes, documents subject to
302s, portions of state investigative file, attorney investigative privilege. Also
( (t) 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
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
EFTA00065067
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 ( ) notes 6(e)
Thru regarding document review an 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 I ) 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
EFTA00065068
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
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 " (N.Y. AUSA)" Work product
P-003679 containing attorney ( ) handwritten notes
Thru
P-003680
Box #1 File folder entitled "Dr. containing Work product
P-003681 attorney ) memo to expert witness and Investigative privilege
Thru handwritten attorney notes
P-003687
Box #1 File folder entitled " 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 (MM.) 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
EFTA00065069
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 " ' containing grand 6(e)
P-003713 jury subpoenas, motion 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 " ocuments 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
EFTA00065070
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 7 of 23
Bates Ran e Descri tion Privile s Asserted
ff
Box #1 Filed folder entitled " Work product
P-004561 containing attorney ( handwritten notes Investigative privilege
Thru of interview
P-004565
Box #1 File folder entitled " 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 ' 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
EFTA00065071
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 " 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
arties to this liti ation
Box #1 File folder entitled 6(e)
P-005301 STATEMENT' containing transcript obtained via Investigative privilege
Thru subpoena
P-005331
Box #1 File folder entitled ' ' 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
Ma 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
EFTA00065072
Case 9:08-cv-80736-KAM Document 212-1 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
EFTA00065073
Case 9:08-cv-80736-KAM Document 212-1 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
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
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
EFTA00065074
Case 9:08-cv-80736-KAM Document 212-1 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 letter (P-008328-P-
008343 [not being withheld as privileged — have
been produced to opposin counsel]); subfolder
entitled "12/19/07
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 11'"
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
EFTA00065075
Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 12 of
23
Bates Range Description Privilege(s) Asserted
Box #2 6/25/2007 Letter from
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 interview of Jane Doe #2 Investigative Privilege
Thru Contains information subject
P-008542 to privacy rights of victims
who are not parties to this suit
Box #2 Handwritten attorney notes regarding May 8, Work product
P-008543 2007 grand jury presentation 6(e)
Thru Investigative privilege
P-008549 Contains information subject
to privacy rights of victims
who are not parties to this suit
Box #2 File folder entitled "Most Recent Indictment & Work product
P-008550 Good Cases" containing draft indictment and 6(e)
Thru legal research Investigative privilege
P-008615 Deliberative process
Contains information subject
to privacy rights of victims
who are not parties to this suit
Box #2 File folder entitled "FBI Summary Charts" Work product
P-008616 containing chart prepared at direction of AUSA, Attorney-Client Privilege
Thru containing victim names, identifying information, 6(e)
P-008686 summary of activity, and other information Investigative privilege
relevant to indictment Contains information subject
to privacy rights of victims
who are not parties to this suit
Box #2 File folder entitled "[Victim name]/Jane Doe #4" Work product
P-008687 containing phone records and meta-analysis of all 6(e)
Thru phone, travel, and grand jury data related to that Investigative privilege
P-008776 victim/witness for indictme
DataSet-9
Unknown
3 pages
Lee Medlin
Manager. Corporate Aviation Services
March 23, 2017
Via E-mail/Facsimile
Darren Indyke, Esq.
6100 Red Hook Quarter, B3
St. Thomas, USVI 00802
Facsimile: 646-350-0378
Dear Mr. Indyke:
This letter is to notify you of the obligations of Plan D, LLC ("Buyer) under
the Aircraft Sale and Purchase Agreement (the "Agreement") dated February
24, 2017 between Buyer and Chevron U.S.A. Inc. ("Seller") for the sale of the
Gulfstream GV-SP Aircraft (G550) (SN 5173) (the "Aircraft") from Seller to
Buyer. Capitalized terms are defined in the Agreement.
The definition of Closing Date specifies that it is to occur within two Business
Days following successful completion of the Inspection, correction of
Inspection Discrepancies, and the Aircraft's return to service by the
Inspection Facility (which is Gulfstream Aerospace Corporation's
("Manufacturer") Westfield Service Center near Springfield, Massachusetts).
Manufacturer's final Aircraft Records and Condition Survey ("Inspection
Report") was delivered to Buyer on Monday, March 20 and the Manufacturer
returned the Aircraft to service on Wednesday, March 22 with all
discrepancies corrected. In accordance with the Agreement, the Closing Date
should be Friday, March 24, 2017. Moreover, earlier this week Seller's
broker arranged with Mr. Visoski on behalf of Buyer a Closing Date of March
24.
However, on Tuesday evening, March 21, Mr. Visoski expressed reservations
about proceeding with the sale given indication in the 2011 Aircraft flight
records of a suspected lightning strike that occurred during a Seller flight in
Corporate Aviation Services
Chevron U.S.A. Inc.
P.O Box 6565. Oakland. CA 94603
Toles Fax
EFTA00622632
Mr. Darren Indyke, Esq.
Page 2
March 23, 2017
2011. This 2011 flight log record titled "Flight Log Maintenance" was noted in
Manufacturer's historical records research as part of the Inspection Report.
However, Manufacturer did not identify the 2011 suspected lightning strike as
a discrepancy in the Inspection Report. As noted, Manufacturer has returned
the aircraft to airworthy status with all discrepancies corrected. Seller's
maintenance records from 2011 noted by Manufacturer were made available
for Buyer's review in January 2017 during a physical inspection of the Aircraft
by Buyer.
Based on Section 5.1(B) and 5.5 of the Agreement, the 2011 suspected
lightning strike does not qualify as an Inspection Discrepancy. To be an
Inspection Discrepancy, a lightning strike would need to constitute material
damage history, the repair of which would constitute a major repair. See
Section 5.1(B)(vii).
Under Section 5.5(ii) and (iii), only in the event of an Inspection Discrepancy
does Buyer have the option to:
- make Buyer's acceptance of the Aircraft conditional on Seller's
correction of Inspection Discrepancies, or
- reject the Aircraft (if Seller is unwilling to deliver the Aircraft at
Closing without Inspection Discrepancies).
As it stands, under Section 5.5(i), within two Business Days of receiving the
Inspection Report, Buyer must accept the Aircraft "as is, where is" and "with
all faults."
Mr. Visoski on behalf of Buyer sent an email Wednesday evening, March 22
indicating that the Closing Date should be postponed in light of (1) the
discrepancies uncovered to date, (2) the fact that the Inspection has not been
completed since Buyer needs to engage inspection professionals other than
Manufacturer, and (3) Seller's duty to correct deficiencies.
Seller does not believe that the Buyer is being reasonable in view of the
Manufacturer's report and return to service. Also, it is not reasonable to
suggest that a suspected lighting strike that occurred in 2011 could be an
Inspection Discrepancy where it never required corrective action over many
years and was not noted by the Manufacturer in the Inspection Report as a
potential issue.
EFTA00622633
Mr. Darren Indyke, Esq.
Page 3
March 23, 2017
As an expression of good faith, Seller agrees to reschedule the Closing Date
from Friday, March 24 to Thursday, March 30, in order to give the Buyer time
to consult with the Buyer's principal and other professionals and perform any
additional inspections at its sole cost.
Seller requests that Buyer prepare for the Closing Date on Thursday, March
30, 2017, including executing and delivering the Acceptance Certificate as
soon as possible.
Seller reserves all rights under the Agreement.
If you wish to discuss, please call me at the number below.
Sincerely,
Lee Medlin
Manager, Corporate Aviation Services
Chevron U.S.A. Inc.
MOS
cc: Mr. Lawrence Visoski (email:
EFTA00622634
DataSet-9
Unknown
3 pages
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203-2740
303-831-7364
Darren Indyke Statement Date: November 30, 2018
Statement No. 310228
Account No. 2592.0002
Page: 1
Re: v. Epstein, et al.
Duplicate
Fees
Hours
11/01/2018 LAM Edit responses, email correspondence with all counsel re. PO, review new
documents; Email correspondence with opposing counsel, serve responses;
telephone call with Indyke and Link 2.60 1,365.00
11/02/2018 LAM Depo prep-gather & organize documents, email correspondence with
paralegal, intemet research, review Epstein depo transcript, review doc
production by defendant Epstein; draft subpoenas to Sugardaddy, research
FIT office of general counsel; email correspondence with Boise et al re.
protective order; telephone client- depo prep 5.40 2,835.00
11/04/2018 LAM Depo prep, FaceTime call with client 7.30 3,832.50
11/05/2018 AML Prepare document production; database organization; review pleadings re
ESI issue 1.40 196.00
LAM Depo prep including call with client (2.8), telephone call with Link, prepare
document production; draft pleading to court re. protective order; email
correspondence with Sigrid re. protective order; office conference with
paralegal re. production, email correspondence with counsel re. protective
order; telephone call with client 7.60 3,990.00
11/06/2018 AML Review productions re flight logs; prepare Dropbox link
for document production & email group; database organization; emails w/
Menninger 1.60 224.00
LAM Email correspondence with counsel conferral request; email correspondence
with court; produce documents, draft letter to court re. protective order, draft
email correspondence to client; telephone call with client 4.80 2,520.00
LAM Travel time (not working on case) 4.00 1,140.00
11/07/2018 LAM Prep for court hearing; court hearing by phone; office conference with client;
prep for depo; telephone call with Link 10.00 5,250.00
11/08/2018 LAM Travel time (not working on case) 8.50 2,422.50
LAM Meeting with client, attend depo 9.50 4,987.50
EFTA00794324
Ghislaine Maxwell Statement Date: 11/30/2018
Account No. 2592.000 Statement No. 3102
Re: v. Epstein, et al. Page No. 2
Hours
11/09/2018 LAM Email correspondence with counsel re. Igor depo (multiple) 0.30 157.50
11/12/2018 AW Review documents re: Zinoviev; prepare deposition materials for L.
Menninger. 1.90 266.00
LAM Email correspondence with counsel re. depo schedule 0.40 210.00
11/13/2018 AW Reviewing documents re: Zinoviev. 1.20 168.00
LAM Email correspondence with counsel re. depo 0.30 157.50
TG Telephone call with client 0.80 420.00
11/14/2018 LAM Draft 3rd party subpoenas; email correspondence with counsel re. depo
reschedule; modify protective order and circulate 2.80 1,470.00
11/15/2018 LAM Draft notices of subpoenas, serve; email protective order to all counsel;
email correspondence with counsel re. conferral 0.60 315.00
11/16/2018 TG Confer with L. Menninger re discovery matters; review Zinoviev deposition
documents 0.50 262.50
LAM Draft letter to court with proposed protective order; serve notices of
subpoenas; telephone call with Walgreens legal department, prepare Duane
Reade subpoena and notice and serve 0.80 420.00
11/18/2018 TG Email to P. Cassell re conferral on discovery issues 0.40 210.00
11/19/2018 TG Emails from L. Menninger re Zinoviev deposition rescheduling 0.20 105.00
TG Review email from L. Menninger re response to P. Cassell conferral issues 0.50 262.50
11/20/2018 TG Emails from L. Menninger re Zinoviev deposition 0.20 105.00
TG Emails to/from P. Cassell and B. Henderson re discovery conferral 0.40 210.00
11/21/2018 TG Conference call with Cassell re conferral on discovery issues; prepare for
same 2.20 1,155.00
TG Research/draft email to Cassell re supplementing discovery responses;
emails to/from L. Menninger re same and re supplemental privilege log 1.30 682.50
TG Review discovery order 0.20 105.00
TG Emails to/from L. Menninger re enforcement of protective order 0.50 262.50
11/24/2018 TG Email from P. Cassell re motion to compel 0.10 52.50
11/26/2018 AML Database organization 0.80 112.00
TG Email re Zinoviev deposition 0.10 52.50
TG Email from M. Schultz re expert disclosure deadline 0.10 52.50
TG Emails from S. Bohrer and J. Wolman re oral argument rescheduling 0.20 105.00
LAM Telephone call with client; telephone call and email correspondence with
Julie Brown and her counsel; telephone call with Link 1.80 945.00
11/27/2018 AML Prepare subpoena production; database organization 0.40 56.00
TG Confer with and emails from/to L. Menninger re expert deadlines; review
scheduling order 0.40 210.00
TG Emails from L. Menninger and A. Lundberg re response to SDT 0.20 105.00
LAM Email correspondence with counsel re. experts; email correspondence for
EFTA00794325
Ghislaine Maxwell Statement Date: 11/30/2018
Account No. 2592.000 Statement No. 3102
Re: v. Epstein, et al. Page No. 3
Hours
subpoenaed entities; review email correspondence from counsel, from FIT
counsel, draft protective order to file with court 0.90 472.50
11/28/2018 ANM Emails re Miami Herald article 0.10 31.50
TG Emails from/to L. Menninger and A. Mueller re J. Alessi deposition and
settlement-agreement issues 0.40 210.00
TG Email from L. Menninger and M. Schultz re expert disclosure deadline 0.10 52.50
11/29/2018 LAM Review news reports, email correspondence with Link 0.70 367.50
For Current Services Rendered 84.50 38,531.00
Advances
11/12/2018 Investigative Services: Forensic Pursuit (e-discovery searches for discovery
responses) 5,393.40
11/13/2018 Transcript Charges: Southern District Reporters PC 82.95
11/15/2018 Charge for Delivery Service: Associated Services 75.00
11/15/2018 Charge for Delivery Service: Countywide Process Service and Investigations 80.00
11/16/2018 Charge for Messenger/Delivery Service: Parcels, Inc 96.60
11/27/2018 Deposition/Transcript Charges: Magna Legal Services 2,254.50
11/30/2018 Charge for Legal Research: Westlaw 180.76
Total Advances 8,163.21
Total Current Work 46,694.21
Previous Balance $19,677.01
Balance Due $66,371.22
Please make checks payable to HADDON MORGAN & FOREMAN
To ensure proper credit to your account PLEASE include your account
number along with your payment. Payments received after the last day of
the month will not be reflected on this statement.
EFTA00794326
DataSet-9
Unknown
7 pages
1 OF 2 150526 WRO BBJ PIC0092015 irri
WORK REQUEST ORDER
PICTON II LTD
VP-BBJ I B737-72U I SN 29273 I YG006
AFT AFL E1T E1C E2T I E2C I APUT I APUC
TO: FROM (CAM):
Seyidt Ersevik Steve Wilson
COMPANY: DATED:
Jet Aviation Geneva 26.05.2014
FAX NUMBER: QUOTATION REFERENCE:
N/A
EMAIL ADDRESS: WORK REQUEST ORDER NUMBER:
[email protected] P1C0092015
W/O ENTRY
ITEM DESCRIPTION
SIGNATURE
1. Comply with 1A/2A CAMP WO attached -"VP-BB) 2A Check 2015".
Comply with Due Maintenance CAMP WO attached - "VP-BBJ Due MX Jun 2015".
2. Compliance with AD 2012-24-08 / SB 737-30A1063 R2
NOTE: KITS provided as ordered with Jet Aviation.
AMOC Letters to be referred if SB 737-30A1063 is not possible to install as is.
(AMOC letters:
1. GAMOC_130S-13-254
2. GAMOC_130S-14-66
3. SB-737-30A1063-02-AMOC-01 = 36 Months
3. Compliance with Task 28-AWL-05 and any other AIR applicable task after AD 2012-24-08 C/W.
4. Compliance with AD 2010-24-11 / SB 737-57A1279 consumables to be ordered ASAP.
NOTE: A/R Tasks (MPD) to be verified N/A before access closure.
5. Compliance with AD 2012-25-05 N/A by PN installed. Please check aircraft and record in WO
accordingly.
6. Compliance with SB 737-28A1206 R3. Revision 2 previously C/W.
7.
THANK YOU
EXPECTED ARRIVAL: 15.06.2015
REQUESTED AVAILABILITY: 26.06.2015
CONTINUED AIRWORTHINESS MANAGEMENT (on behalf of PICTON II Ltd)
Qjet Aero I Switzerland I [email protected] I Tel:
EFTA01198322
2 OF 2 150526 WRO BB] PIC0092015 ri
WORK REQUEST ORDER
INSTRUCTIONS RELEVANT - CERTIFICATE OF RELEASE TO SERVICE (CRS)
1. After entry of Work Request Items into MRO system, Planning or Technical
Support shall sign in the allocated space. Signature indicates that request(s)
have been transferred to the actual project.
2. Item numbers showing "*" have been amended/added after original order
was issued.
3. Certificate of Release to Service (CRS) shall refer Work Request Order
Number and encompass all requested items unless otherwise specified or
communicated.
4. Work Order entries (items) shall detail maintenance reference/specific
chapters in all cases. Generic references and vague statements will not be
accepted. AMM revision status shall also be indicated.
5. CRS shall comprise Flight Log Entry/Stamp/Signature and printed Certificate
for Aircraft/Engine/APU Logbook(s).
INSTRUCTIONS RELEVANT - CONTINUED AIRWORTHINESS MANAGEMENT
1. Before aircraft departure CRS, WO and Flight Log Entry shall be scanned and
sent to the Continued Airworthiness Manager (CAM) for review.
2. After project closing, all CAMP Cards including CRS shall be scanned and sent
to CAMP SYSTEMS for update within 5 working days.
3. Original Work Package documents shall be handed to the Operator or CAM as
arranged.
Note: There is no requirement for originals/copies of procedures used during
maintenance to be provided.
CONTINUED AIRWORTHINESS MANAGEMENT (on behalf of PICTON II Ltd)
Qjet Aero I Switzerland I [email protected] I Tel: +41 76 510 2654
EFTA01198323
CAMP Work Order Contents Report
SERIAL: 29273 (YG006) REGNO : VP-BBJ MODEL NAME : BBJ 737-700IGW/-800/-900ER WORK ORDER #: VP-BBJ 2A CHECK 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.0 050020 A-2 CHECK OPEN
1.1 352003 VISUAL INSPECTION OXYGEN SYS. BOX(S) OPEN
1.2 352004 VISUAL INSPECTION OXYGEN SYS MASK(S) OPEN
1.3 21-860-01 INSPECT AND CLEAN OR REPLACE THE LEFT HAND A/C COALESCER BAG OPEN
1.4 21-860-02 INSPECT AND CLEAN OR REPLACE THE RIGHT HAND NC COALESCER BAG OPEN
1.5 33.090.00 GENERAL VISUAL INSPECTION OF THE TRANSPARENT FAIRING LENS LOCATED ON THE FORWARD LEADING OPEN
EDGE OF THE WINGLET, LEFT AND RIGHT
1.6 25.020.00 DETAIL INSPECTION OF THE CAPTAIN, FIRST OFFICER, FIRST OBSERVER AND SECOND OBSERVER (IF OPEN
INSTALLED) SEAT HARNESSES, CROTCH STRAPS, AND SHOULDER BELTS (AS APPLICABLE) FOR WEAR,
CONDITION AND SECURITY.
1.7 28.2001 PATS OPERATIONAL CHECK OF THE AUXILIARY FUEL CONTROL UNIT OPEN
1.8 23.11000 (FAR 91.207) INSPECT (FIXED) EMERGENCY LOCATOR TRANSMITTER IAW FAR 91.207(D) OPEN
1.9 54.090.01 FUNCTIONALLY CHECK THE LEFT ENGINE FORWARD STRUT AND AFT STRUT FAIRING DRAINS. OPEN
1.10 54.090.02 FUNCTIONALLY CHECK THE RIGHT ENGINE FORWARD STRUT AND AFT STRUT FAIRING DRAINS. OPEN
1.11 385015 CLEAN AFT GALLEY SINK DRAIN FILTER OPEN
1.12 21.14001 CHECK THE LEFT WATER SEPARATOR INDICATION DISK (WITH THE AIR CONDITIONING SYSTEM OPERATING) OPEN
1.13 21.14002 CHECK THE RIGHT WATER SEPARATOR INDICATION DISK (WITH THE AIRCONDMONING SYSTEM OPERATING) OPEN
1.14 23.040.00 OPERATIONAL CHECK OF THE VOICE RECORDER AND RECORDER INDEPENDENT POWER OPEN
SUPPLY (RIPS) (IF INSTALLED).
1.15 27.102.00 LUBRICATE STABILIZER TRIM ACTUATOR AND ACTUATOR GIMBAL PINS AND BALLNUT OPEN
1.16 27.17001 LUBRICATE LEFT WING TRAILING EDGE FLAP ACTUATION MECHANISM OPEN
1.17 27.17002 LUBRICATE RIGHT WING TRAILING EDGE FLAP ACTUATION MECHANISM OPEN
1.18 32.010.01 CLEAN LEFT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.19 32.010.02 CLEAN RIGHT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.20 32.020.01 SERVICE LEFT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.21 32.020.02 SERVICE RIGHT MAIN LANDING GEAR ASSEMBLY SHOCK STRUT OPEN
1.22 32.030.01 LUBRICATE LEFT MAIN LANDING GEAR ASSEMBLY OPEN
1.23 32.030.02 LUBRICATE RIGHT MAIN LANDING GEAR ASSEMBLY OPEN
1.24 32.060.00 CLEAN NOSE LANDING GEAR SHOCK STRUT OPEN
1.25 32.070.00 SERVICE NOSE LANDING GEAR SHOCK STRUT OPEN
1.26 32.080.00 LUBRICATE NOSE LANDING GEAR ASSEMBLY OPEN
1.27 32.27001 VISUAL CHECK LEFT BRAKE WEAR PINS FOR MINIMUM EXTENSION OPEN
1.28 32.27002 VISUAL CHECK RIGHT BRAKE WEAR PINS FOR MINIMUM EXTENSION OPEN
1.29 32.80000 EXTERNAL ZONAL INSPECTION (GV) NOSE LANDING GEAR AND LANDING GEAR DOORS (FROM GROUND) OPEN
PERFORM AN EXTERNAL ZONAL INSPECTION (GV) OF THE NOSE LANDING GEAR AND LANDING GEAR DOORS.
INSPECTION IS ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. (EZAP)
1.30 32.80401 EXTERNAL ZONAL INSPECTION (GV) LEFT MAIN LANDING GEAR AND LANDING GEAR DOORS (FROM GROUND) OPEN
PERFORM AN EXTERNAL ZONAL INSPECTION (GV) OF THE LEFT MAIN LANDING GEAR AND LANDING GEAR
DOORS. INSPECTION IS
ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS
1.31 32.80802 EXTERNAL ZONAL INSPECTION (GV) RIGHT MAIN LANDING GEAR AND LANDING GEAR DOORS (FROM GROUND) OPEN
PERFORM AN EXTERNAL ZONAL INSPECTION (GV) OF THE RIGHT MAIN LANDING GEAR AND LANDING GEAR
DOORS. INSPECTION IS
ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS
26-MAY-2015 © CAMP SYSTEMS 1 of 3
EFTA01198324
CAMP Work Order Contents Report
SERIAL: 29273 (YG006) REGNO : VP-BBJ MODEL NAME : BBJ 737-700IGW/-800/-900ER WORK ORDER #: VP-BBJ 2A CHECK 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.32 33.010.00 OPERATIONAL CHECK EMERGENCY LIGHTS OPEN
1.33 53.800.00 EXTERNAL ZONAL INSPECTION (GV) OF THE LOWER Ricci aCE. THE NOSE LANDING GEAR WHEEL WELL AND OPEN
MAIN LANDING GEM WHEEL WELL ARE ALSO INCLUDED. INSPECTION IS ACCOMPLISHED FROM THE GROUND,
WITHOUT THE USE OF STANDS OR LADDERS. NO ADDMONAL ACCESS PANELS REQUIRED (EZAP)
1.34 53.812.00 INTERNAL ZONAL INSPECTION (GV) FORWARD CARGO COMPARTMENT SECTION 43, STATION 396 TO OPEN
FORWARD CARGO COMPARTMENT AFT BULKHEAD
1.35 53.830.00 INTERNAL ZONAL INSPECTION (GV) AFT CARGO COMPARTMENT - SECTION 46 AND 47 (PART), STATION 727 OPEN
TO STATION 947.5
1.36 53.844.00 EXTERNAL ZONAL INSPECTION (GV) OF THE WING TO BODY FAIRING. INSPECTION IS ACCOMPLISHED FROM OPEN
THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRE
1.37 53.894.00 EXTERNAL ZONAL INSPECTION (GV) OF THE FUSELAGE. INSPECTION IS ACCOMPLISHED FROM THE GROUND, OPEN
WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED
1.38 55.800.00 EXTERNAL ZONAL INSPECTION (GV) VERTICAL FIN AND HORIZONTAL STABILIZER. INSPECTION IS OPEN
ACCOMPLISHED FROM THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS
PANELS REQUIRED
1.39 57.802.01 EXTERNAL ZONAL INSPECTION (GV) LEFT WING INSPECTION IS ACCOMPLISHED FROM THE GROUND, WITHOUT OPEN
THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED.
1.40 57.872.02 EXTERNAL ZONAL INSPECTION (GV) RIGHT WING INSPECTION IS ACCOMPLISHED FROM THE GROUND, OPEN
WITHOUT THE USE OF STANDS OR LADDERS. NO ADDITIONAL ACCESS PANELS REQUIRED.
1.41 70800.01 EXTERNAL ZONAL INSPECTION (GV) NO. 1ENGINE STRUT FAIRINGS. INSPECTION IS ACCOMPLISHED FROM OPEN
THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO
ADDITIONAL ACCESS PANELS REQUIRED.
1.42 70.810.02 EXTERNAL ZONAL INSPECTION (GV) NO. 2 ENGINE STRUT FAIRINGS INSPECTION IS ACCOMPLISHED FROM OPEN
THE GROUND, WITHOUT THE USE OF STANDS OR LADDERS. NO
ADDITIONAL ACCESS PANELS REQUIRED
1.43 52.150.00 LUBRICATE AIRSTAIR DOOR SYSTEM (INCLUDES TWO ROLLERS, CARRIAGE DRIVE BEARING, DRIVE NUT IN OPEN
JACK SCREW, LOCK PIN GRFACF FITTING AND FOUR BEARINGS IN THE CARRIAGE ROLLERS).
1.44 26.450.00 INSPECT (DETAILED) THE PORTABLE HALON FIRE EXTINGUISHERS FOR PROPER PRESSURE (IF GAUGE OPEN
INSTALLED), WEIGHT AND CONDITION.
1.45 050010 A-1 CHECK OPEN
1.46 257001 GENERAL VISUAL INSPECTION HEADLINER CEILING PANELS OPEN
1.47 257002 GENERAL VISUAL INSPECTION INTERIOR BULKHEADS OPEN
1.48 257003 GENERAL VISUAL INSPECTION COMPARTMENT DOORS OPEN
1.49 257004 GENERAL VISUAL INSPECTION SEATS ANDTABLES OPEN
1.50 257005 GENERAL VISUAL INSPECTION CLOSET AND CABINETS OPEN
1.51 257006 GENERAL VISUAL INSPECTION CLOSET AND CABINET DOORS OPEN
1.52 257007 GENERAL VISUAL INSPECTION BED AND DIVANS OPEN
1.53 257011 CHECK SAFETY BELTS OPEN
1.54 352002 GENERAL VISUAL INSPECTION CHEMICAL 02 MASK OPEN
1.55 381120 CHECK WATER/WASTE DRAIN LINES OPEN
1.56 385010 CLEAN WATER/WASTE INSIDE FILTER OPEN
1.57 57.950.01 EXTERNAL ZONAL INSPECTION OF THE LEFT WINGLET OPEN
1.58 57.952.01 INTERNAL ZONAL INSPECTION LEFT WINGLET OPEN
1.59 57.960.02 EXTERNAL ZONAL INSPECTION OF THE RIGHT WINGLET OPEN
26-MAY-2015 © CAMP SYSTEMS 2 of 3
EFTA01198325
CM,F,11.,„ Work Order Contents Report
SERIAL : 29273 (YG006) REGNO : VP-BIM MODEL NAME : BBJ 737-7001GW/-800/-900ER WORK ORDER #: VP-BI3J 2A CHECK 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.60 57.962.02 INTERNAL ZONAL INSPECTION OF THE RIGHT WINGLET OPEN
1.61 31055.00 FUNCTIONAL CHECK THE EMERGENCY LIGHTING BATTERY PACKS FOR CAPACITY (15 MIN. MINIMUM) AND ONE OPEN
COMPLETE DEEP CYCLE.
1.62 72.02001 DETAILED INSPECTION OF LEFT ENGINE INLET MD FM BLADES. OPEN
1.63 72.02002 DETAILED INSPECTION OF RIGHT ENGINE INLET AND FM BLADES OPEN
Prepared By: Date:
Approved By: Date:
26-MAY-2015 C) CAMP SYSTEMS 3 of 3
EFTA01198326
CAMP Work Order Contents Report
SERIAL: 29273 (YG006) REGNO : VP-BBJ MODEL NAME : BBJ 737-700IGW/-800/-900ER WORK ORDER #: VP-BBJ DUE MX JUN. 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
1.0 737.28Al206 R3 FUEL - DISTRIBUTION - CENTER FUEL TANK BOOST PUMP AUTO SHUTOFF AND MASTER CAUTION LOGIC OPEN
CHANGE, SERVICE BULLETIN
2.0 252501 VISUALLY CHECK FORWARD ENTRY DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER OPEN
PRESSURE
3.0 252502 VISUALLY CHECK FORWARD SERVICE DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER OPEN
PRESSURE
4.0 252503 VISUALLY CHECK AFT ENTRY DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER PRESSURE OPEN
5.0 252504 VISUALLY CHECK AFT SERVICE DOOR EMERGENCY ESCAPE SLIDE PRESSURE BOTTLE FOR PROPER PRESSURE OPEN
6.0 FM 2005-18.23 CORROSION PROTECTION OF THE ELECTRICAL CONNECTORS IN THE MAIN WHEEL WELL OPEN
7.0 FM 2006-21-01 PART 1 FLIGHT CONTROLS AILERON AND AILERON TRIM CONTROL SYSTEM - MEASURE THE FREEPIAY OF BOTH OPEN
AILERON CONTROL BALANCE TABS
8.0 FM 2006.21.01 PART 2 FLIGHT CONTROLS AILERON AND AILERON TRIM CONTROL SYSTEM - REPETATIVE LUBRICATION OPEN
9.0 FM 2011-27.03 PARA (G)(1)(I)(1) DETAILED INSPECTION TO PREVENT AN UNDETECTED FAILURE OF THE PRIMARY LOAD PATH FOR THE OPEN
BALLSCREW IN THE DRIVE MECHANISM OF THE HSTA AND SUBSEQUENT WEAR AND FAILURE OF THE
SECONDARY LOAD PATH IN ACCORDANCE WITH SERVICE BULETIN 737.27A1277 R2
10.0 29-230-00 OPERATIONAL CHECK STANDBY RUDDER SYSTEM TO INCLUDE OBSERVING LOW PPEccatc LIGHT OPEN
ILLUMINATION AND THEN EXTINGUISHING.
11.0 24-120-00(001.1) RESTORE MAIN BATTERY OPEN
12.0 24-120-00(002.1) RESTORE AUXILIARY BATTERY OPEN
13.0 254206 LAERDAL HEARTSTART FR DEFIBRILLATOR PADS OPEN
14.0 081001 WEIGHT CHECK OF AIRCRAFT OPEN
15.0 252901 CAPTAIN LIFE JACKET OPEN
16.0 252902 FIRST OFFICER LIFE JACKET OPEN
17.0 252903 FIRST OBSERVER LIFE JACKET OPEN
18.0 252904 NO. 1 FORWARD FLIGHT ATTENDANT LIFE JACKET OPEN
19.0 252905 NO. 2 FORWARD FLIGHT ATTENDANT LIFE JACKET OPEN
20.0 252906 NO. 1 AFT FLIGHT ATTENDANT LIFE JACKET OPEN
21.0 252907 NO. 2 AFT FLIGHT ATTENDANT LIFE JACKET OPEN
22.0 252909 SECOND OBSERVER LIFE JACKET OPEN
23.0 256323 (001.1) OPERATIONAL CHECK OF THE NO. 1 FORWARD EMERGENCY FLASHLIGHT OPEN
24.0 256323 (002.1) OPERATIONAL CHECK OF THE NO. 2 FORWARD EMERGENCY FLASHLIGHT OPEN
25.0 256323 (003.1) OPERATIONAL CHECK OF THE NO. 1 COCKPIT FLASHLIGHT OPEN
26.0 256323 (004.1) OPERATIONAL CHECK OF THE NO. 2 COCKPIT FLASHLIGHT OPEN
27.0 256323 (005.1) OPERATIONAL CHECK OF THE NO. 1 AFT EMERGENCY FLASHLIGHT OPEN
28.0 256325 (003.1) OPERATIONAL CHECK OF THE CARGO NET OPEN
29.0 347105 (1) 8I-ANNUAL CHECK EGPWS TERRAIN DATABASE VERSION STATUS OPEN
30.0 33-060-00 RESTORE EMERGENCY LIGHTING BATTERY PACK (TWO OR MORE COMPLETE DEEP CYCLES) BATTERY CAPACITY OPEN
TO REQUIRED STANDARD
31.0 25-310.00 (002.1) RESTORE NO. 2 LIFE RAFT PRESSURE BOTTLE OPEN
32.0 25-420-00 (001.1) RESTORE FORWARD FIRST AID KIT OPEN
33.0 25-420-00 (002.1) RESTORE AFT FIRST AID KIT OPEN
34.0 25-430-00 (001.1) RESTORE MEDAIRE BLUE FIRST AID MEDICAL KIT OPEN
26-MAY-2015 © CAMP SYSTEMS 1 of 2
EFTA01198327
CAMP Work Order Contents Report
SERIAL: 29273 (YG006) REGNO : VP-BBJ MODEL NAME : BBJ 737-700IGW/-800/-900ER WORK ORDER #: VP-BBJ DUE MX JUN. 2015
DATE IN : UTC:15-Jun-2015 12:00 AM DATE OUT : UTC:26-Jun-2015 12:00 AM ICAO : SERVICE CENTER : JET AVIATION (GENEVE) S.A.
SORT ITEM NO DESCRIPTION STATUS
COMPLIANCE NEXT DUE TIME
REMAINING
35.0 38-040.00 RESTORE WASTE DRAIN BALL VALVE THE WASTE DRAIN BALL-VALVE BY REPLACING SPA' S (2) (OFF OPEN
AIRCRAFT)
36.0 FM 2015-0402 NO. 1ENGINE - ENGINE FUEL AND CONTROL - MODIFY THE ENGINE BY REMOVING FULL AUTHORITY DIGITAL OPEN
ENGINE CONTROL (FADEC) SOFTWARE, VERSION 7.B.V4 OR EARLIER, INSTALLED IN THE ELECTRONIC ENGINE
CONTROL (EEC)
37.0 FM 2015-0402 NO. 2 ENGINE - ENGINE FUEL AND CONTROL - MODIFY THE ENGINE BY REMOVING FULL AUTHORITY DIGITAL OPEN
ENGINE CONTROL (FADEC) SOFTWARE, VERSION 7.B.V4 OR EARLIER, INSTALLED IN THE ELECTRONIC ENGINE
CONTROL (EEC)
3&0 25-300-00 (002.1) INSPECT AFT LIFE RAFT OPEN
39.0 25-300-00 (003.1) INSPECT NO. 3 LIFE RAFT OPEN
40.0 26-330-00 (002.1) REPLACE (LRD2) CARGO FIRE EXTINGUISHER BOTTLE AFT SQUIB OPEN
41.0 25-6000 GENERAL VISUAL INSPECTION OF ALL COCKPIT / CABIN EMERGENCY EQUIPMENT OPEN
42.0 28-054.00 OPERATIONAL CHECK (BITE) THE FUEL PUMP GFI RELAY OPEN
43.0 28-056.00 FUNCTIONALLY CHECK THE CENTER TANK FUEL BOOST PUMP POWER FAILED ON PROTECTION SYSTEM OPEN
44.0 28-115-00 FUNCTIONALLY CHECK THE CENTER TANK BOOST PUMP AUTO SHUTOFF SYSTEM OPEN
45.0 28-AWL-19 REVIEW CENTER TANK FUEL BOOST PUMP AUTOMATIC SHUTOFF SYSTEM OPEN
46.0 28-AWL-20 REVIEW OVER-CURRENT AND ARCING PROTECTION ELECTRICAL DESIGN FEATURES OPERATION BOOST PUMP OPEN
GROUND FAULT INTERRUPTER (GFI)
47.0 28-AWL-23 FUNCTIONALLY TEST CENTER TANK FUEL BOOST PUMP POWER FAILED ON PROTECTION SYSTEM. OPEN
48.0 737015 (1) ANNUAL CHECK OF EEC#1 & EEC#2 SOFTWARE ENGINE FUEL AND CONTROL ECU SOFTWARE STATUS OPEN
49.0 FM 2011.27.03 PARA (G)(1)(I)(2) LUBRICATE TO PREVENT AN UNDETECTED FAILURE OF THE PRIMARY LOAD PATH FOR THE BALLSCREW IN THE OPEN
DRIVE MECHANISM OF THE HSTA AND SUBSEQUENT WEAR AND FAILURE OF THE SECONDARY LOAD PATH IN
ACCORDANCE SERVICE BULLETIN 737-27A1277 R2
50.0 347101 UPDATE NAV DATABASE OPEN
Prepared By: Date:
Approved By: Date:
26-MAY-2015 © CAMP SYSTEMS 2 of 2
EFTA01198328
DataSet-9
Unknown
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. Joseph Recarey Deposition Transcript (Vol. I)
GJ SUBPOENA RESPONSE 001009 001137
BSF ShareFile Materials
(March 1, 2019)
EFTA00090979
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. Joseph Recarey 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)
EFTA00090980
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)
EFTA00090981
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)
EFTA00090982
DataSet-10
Unknown
2 pages
To:
From: reg y er
Sent Wed 4/9/2014 10:50:11 AM
Subject: Re: Jeffrey Epstein
Thanks!
On Apr 9, 2014 6:49 AM, Lesley Groff a> wrote:
I hope you rec'd the answer earlier...it is:
On Apr 9, 2014, at 3:23 AM, "Greg Wyler" vvrote:
> Is the WiFi available to ests here on the island? If so, what is the password? On Apr 8, 2014
2:19 PM, te:
> tremendous. thanks
> On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote:
>> My cell is:
>> See you soon.
>> Original Message
>> From:
>> Sent: Tuesda Aril 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 T
eterboro to 7pm tonight...
>> Jeffrey's home address:
>> 9 East 71st Street Between 5th and Madison
>> Is your cell number:
>> If you need to call m
>> Thanks for the info!
>1=
>>
EFTA_R1_00725996
EFTA02108080
>> 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 gue
ssing 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 A wrote:
>>> Hello Greg...Jeffrey says you would like a ride tonight on his plane to St. Thomas...He also h
as 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 Tet
erboro?...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,
>>>
>>>
EFTA_R1_00725997
EFTA02108081
DataSet-9
Unknown
21 pages
Filing Ii 37557658 E-Filed 02/08/2016 06:20:47 PM
IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIVIL DIVISION
BRADLEY J. EDWARDS, and CASE. NO. CACE 15-000072
PAUL G. CASSELL,
Plaintiffs,
v.
ALAN DERSHOWITZ,
Defendant.
RESPONSE TO DEFENDANT ALAN DERSHOWITZ'S MOTION FOR
CLARIFICATION OF CONFIDENTIALITY ORDER OR RELIEF FROM THAT ORDER
Non-Party , by and through undersigned counsel, hereby responds to
Defendant Alan Dershowitz's Motion for Clarification of Confidentiality Order or Relief From
that Order and states as follows:
FACTUAL BACKGROUND
On November 12, 2015 this Court issued an Order granting in part, non-party
IM ; Motion to Quash the subpoena served by Defendant Alan Dershowitz and ordered
protective limits relating to her deposition. See Exhibit A, November 12, 2015 Order. On
December 18, 2016, this Court entered a Confidentiality Order holding that non-part
deposition would be confidential. See Exhibit B, December 18, 2015 Confidentiality
Order. On January 16, 2016, Ms=testified at her deposition in accordance with this
Court's Order. The deposition was labelled confidential in accordance with this Court's Order.
As the Court knows, Ms. was a victim of sexual trafficking when she was a minor child.
Indeed, the U.S. Attorney's Office for the Southern District of Florida has specifically recognized
*** FILED: BROWARD COUNTY. FL HOWARD FORMAN. CLERK 2/8/2016 6:20:46 PM
EFTA01111123
her as a "victim" of federal sex offenses. Unsurprisingly, her deposition contains highly sensitive
infonnation about her experiences as a minor child, including detail descriptions of sexual crimes
committed against her.
ARGUMENT
1. Non-Party Agrees That Her Deposition Should Be Provided
Confidentially To Law Enforcement to Investigate All The Crimes Committed
Against Her
Defendant Dcrshowitz seeks to have the Court grant an exception to the confidential nature
of the deposition so that it can be provided to the Office of the State Attorney and the Office of the
United States Attorney for investigative purposes. Specifically, Defendant Dcrshowitz states in
his motion that he is hoping to have law enforcement investigate whether ommitted
Ms.a
perjury by stating in her previously filed affidavit that it is her recollection that she witnessed
former President Bill Clinton on Jeffrey Epstein's island in the United States Virgin Islands
('USVI- )1.
Setting aside Defendant Dershowitz's baseless claims of perjury, Ms agrees that
her confidential deposition should be provided to law enforcement, including the United States
Attorney and the State Attorney in each jurisdiction where any alleged crimes occurred so that
they may investigate all of the crimes committed against her when she was a minor child. To
ensure that justice is served and that Defendant Dershowitz's request is not just another charade
designed only to bully a sexual abuse victim, Ms
a l sks the Court to impose the following
reasonable conditions relating to the disclosure:
• Mr. Dcrshowitz agrees and is directed to cooperate with authorities and answer all
questions relating to the investigation of crimes against Ms.
Defendant Dcrshowitz conveniently ignores that publicly available flight logs of Jeffrey Epstein's private
planes demonstrate that President Clinton travelled with Jeffrey Epstein and others to various locations
throughout the world including Europe, Africa and Asia. See Exhibit C, Excerpts of Flight Logs from
Jeffrey Epstein's private plane.
EFTA01111124
• Mr. Dershowitz agrees to make his client. Jeffrey Epstein. and others with relevant
testimony and with whom he has testified he shares a "common interest" — at least Epstein
and Maxwell — available to any law enforcement agency reviewing any alleged criminal
activities: or in the alternative, to attest to this Court that those necessary witnesses have
consented to full cooperation in the investigation Mr. Dershowitz is seeking permission to
initiate.
• Mr. Dershowitz agrees to waive the statute of limitations in all jurisdictions for any
criminal conduct he participated in or was aware of relating to Ms.
n io that law
enforcement can pursue any necessary charges. Defendant Dershowitz proclaimed that he
was willing to waive any statute of limitation for criminal conduct so this should not be an
issue. See Exhibit D, January 12, 2016 Deposition Transcript of Alan Dershowitz at 395.
"I had talked about the statute of limitations for criminal purpose was what I said. that I
would waive the statute of limitations for criminal purposes."
• Mr. Dershowitz agrees to provide the names and contact information for each State
Attorney and United States Attorney for which he has or is planning to rovide
information relating to Ms. and agrees to jointly, with Ms. counsel,
request that the State Attorney and United States Attorney, in the r isdictions,
investigate all potential criminal conduct. Both parties may provide any relevant
information they have that may assist the authorities with their investigation.
• For all other purposes non-party Ms. January 16, 2016 deposition transcript shall
remain confidential and sealed other than for confidential disclosure to law enforcement as
described above.
2. Mr. Dershowitz Has No "Evidence" of Perjury And Instead Is Simply Trying To
Bully This Victim
As explained above, Defendant Dershowitz wrongly suggests to this Court that non-party
Virginia has committed perjury in an effort to taint the Court against this victim. His only
"evidence" of this alleged perjury is a self-serving opinion from his retained expert that an
"absence of records" in response to a FOIA request, establishes that former President Clinton was
never on Jeffrey Epstein's island in the USVI. Defendant Dershowitz misrepresents the
government's response. The government is only required to conduct a reasonable search of
readily accessible records. Accordingly. an "absence of records" response does not mean that
records do not exist. It simply means that in the course of the search, no records were found. See
Cunningham v. U.S. Dept. ofJustice, 961 F.Supp. 2d 226, 236 (D.C. 2013) (court reasoning that
"[t]he adequacy of a search is measured by a standard of reasonableness... The question is not
3
EFTA01111125
whether other responsive records may exist, but whether the search was adequate."); Wilbur v.
C.I.A., 355 F.3d 675, 678 (D.C. 2004) (court explaining that "the agency's failure to turn up a
particular document, or mere speculation that as yet uncovered documents might exist, does not
undermine the determination that the agency conducted an adequate search for the requested
records."). Moreover, when dealing with a former President's security detail travel, there are a
number of reasons why the government may not disclose those records.
As explained above, public flight records from Jeffrey Epstein's private plane show that
President Clinton traveled with Jeffrey Epstein on multiple occasions. Nevertheless, if Defendant
Dershowitz wants to pursue this issue before the Court, then he needs to produce for deposition
testimony in this case and the proposed criminal investigation, the other witnesses that were
present on the island at the time former President Clinton was alleged to have visited, including
his client Jeffrey Epstein, and Ohislaine Maxwell, to whom he has testified he is party to a joint
defense agreement. It is worth noting on that point, that despite Mr. Epstein's counsel's
attendance at depositions in this case, and Defendant Dershowitz's claim that Mr. Epstein is still
his client, Mr. Epstein has taken extreme measures to avoid being deposed in this case despite
being ordered to deposition by this Court.
Indeed, it is also noteworthy that during Defendant Dershowitz's recent deposition,
counsel for Mr. Edwards and Mr. Cassell asked Defendant Dershowitz the following question:
"WallIMM lying when she said Jeffrey Epstein socialized with Bill Clinton during the
relevant time period?" Depo Tr. Of Alan Dcrshowitz, Vol. 4, January 12, 2016 at 511. Before
Defendant Dershowitz could answer, Mr. Dershowitz's legal counsel interposed an attorney-client
privilege objection. Id. Perhaps Mr. Epstein's defense counsel can provide to the Court an
appropriate privilege log regarding that objection — and all the communications between Mr.
Epstein and Defendant Dershowitz that would have been revealed in answer to that question — so
that the Court will have the benefit of a full record in niling on this motion.
4
EFTA01111126
CONCLUSION
WHEREFORE, Non-Party respectfully requests that this Court allow a
limited release of her confidential deposition transcript to law enforcement subject to the terms set
forth above on pages 2-3.
Dated: February 8, 2016
Respectfully submitted,
BOWS", SCHILLER & FLEXNER 1,1,1)
401 East Las Olas Boulevard, Suite 1200
Fort Lauderdale, Florida 33301
Telephone: (954) 356-0011
Facsimile: (954) 356-0022
By: /s/Sigrid S. McCawley
Sigrid S. McCawley, Esq.
Florida Bar No. 129305
Attorneyfor Non-Pan)ill=l1
5
EFTA01111127
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on February 8. 2016, a true and correct copy of the foregoing,..
was served by Electronic Mail to the individuals identified below.
By: /s/Sigrid S. McCawley
Sigrid S. McCawley
Thomas E. Scott Jack Scarola
SEARCY DENNEY SCAROLA BARNHART
MIT a ra & SHIPLEY, P.A.
111.1.11.. P.A. 2139 Palm Bcachtakcs Blvd.
9150 S. Dadeland Blvd., Suite 1400 West Palm Beach, FL 33409-6601
Attorneyfor Mahal&
Richard A. Sim son
ary t. or a
WILEY REIN, LLP
1776 K Street NW
Washington, U.C. 20006
Counselfor Defendant Alan Dershowitz
6
EFTA01111128
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