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From: Sigrid McCawley < >
Subject: RE: Depo
Date: 20 November 2018 at 08:46:13 GMT
To:
Cc: Stan Pottin , "Paul Cassell
, Meredith Schultz
"Brittany Henderson
Hell that the issues
with and make tasks requiring
concentration, like a deposition, very difficult and they should be avoided until you have
been which will likely be in mid January
Thank you.
Sent by Boxer
On November 19, 2018 at 4:57:11 PM EST, Sigrid McCawley <
wrote:
Thanks for the update and I am so sorry to hear about In
addition to the travel could you see if the that the
and you will not be in a position to do anything that
involves work, including sitting through a deposition? (Or maybe someone else
on the team has better language to propose). It is fine if it is in — we
can
Thank you,Sigrid
Sigrid McCawleyPartner
BOIES SCHILLER FLEXNER
L LP
Fort
Lauderdale, FL. 33301
www.bsfllp.com
EFTA00143682
From: [mailto ] Sent: Monday,
November 19, 2018 4:46 PMTo: Sigrid McCawleyCc: Stan Pottinger;
Paul Cassell ); Meredith Schultz;
Brittany Henderson ( Subject: Re: Depo
Hi Sigrid,
I was at the
All good now and whilst I was there asked them about the
have an a pointment at 12pm tomorrow with the
and travel dates. Unfortunate it will be in but you'll have that by
tomorrow. You also have the records which shows my
My personal preference is to do the deposition early-mid January as I am still
never min oin a e osition on top o t at. e
I also also starting to move house in the next week, which I have no idea how I will
manage but at this moment in time I don't think I will be able to handle doing the
deposition before Christmas. There is time in January?
Please please can you do your best to delay my deposition until I am well and able.
Kind Regards
On 19 Nov 2018, at 21:02, Sigrid McCawley wrote:
Hello — We informed E stein counsel that you are not able to
travel next week to As expected, they are requesting a
Are you able to get a
and are not able to
travel until Mid January? Please don't have them put a lot of detail in it — just a
As you cannot travel, we offered that they could take the deposition in as
an alternative. We are waiting to hear back from them on those possible
EFTA00143683
arrangements.
Thank you and hope you are doing great,Sigrid
Sigrid McCawleyPartner
BOIES SCHILLER
FLEXNER LLP
Fort
Lauderdale, FL, 33301
www.bsfllp.com
The information contained in this electronic message is confidential information intended only for the use
of the named recipients) and may contain information that, among other protections, is the subject of
attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the
reader of this electronic message is not the named recipient, or the employee or agent responsible to
deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or
other use of this communication is strictly prohibited and no privilege is waived. If you have received this
communication in error, please immediately notify the sender by replying to this electronic message and
then deleting this electronic message from your computer. [v.1 08201831BSFJ
EFTA00143684
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From:
To:
Cc:
Subject: Re: Epstein
Date: Fri, 30 Nov 2018 14:32:50 +0000
Importance: Normal
Thanks. And in either the state or federal action, has there been motion practice in which deposition transcripts
have been filed? Motion for summary judgement, for example?
Sent from my iPhone
> On Nov 30, 2018, at 9:28 AM, wrote:
>
> It's in Palm Beach County Circuit Court. It's not the lawsuit the victims filed against the government to
invalidate the NPA. And it's not one of the suits the victims filed against Epstein. It's a lawsuit that an attorney
who represented multiple victims filed against Epstein for malicious prosecution. Sort of a complicated
background: previously Epstein sued the lawyer, claiming that the lawyer was involved in an unrelated fraud that
the lawyer's law partner was convicted of-- the fraud related to an Epstein business. The lawyer is now suing
Epstein for malicious prosecution, claiming that he wrongfully filed the old lawsuit in retaliation for representing
Epstein's victims.
>
> .
> From: C • •i IJSANYS)
> Sent: 11 allovember 30 2018 9:25 AM
> To:
> Cc:
> Subject: pstem
>
> The December 4 trial - is that the one against DOJ or against Epstein? State or federal court?
> Sent from my iPhone
EFTA00104349
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From: "Gmax"
To: [email protected]>
Subject:
Date: Fri, 18 Mar 2011 13:10:06 +0000
Can I have VR deposition please ASAP
Thx
EFTA00655199
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From: Lesley Groff
Sent: Thursday, Marc , :
To: Jeffrey Epstein
Subject: Chet Brewer
Please call Chet Brewer re the Sitrick Deposition Order. He has stepped =ut for lunch but should be back in an hour or
so.
Ela ?xml version=.0" encoding=TF-8"?>
conversation-id
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date-last-viewed
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date-received
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flags
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gmail-label-ids
6
2
remote-id
491737
1
EFTA_R1_01637247
EFTA02506870
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From: David Mitchell <
To: J
Subject: Re:
Date: Thu, 11 Oct 2018 19:26:44 +0000
I will return his call , in deposition
DAVID MITCHELL
Mitchell Holdings LLC
745 Fifth Avenue
New York NY 10151
USA
On Oct 11, 2018, at 12:18 PM, J wrote:
you said you would know the price of the sculptrues today> nu?
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation®gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA01020078
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IC I IC I ( \ I I I) l l) \ I I I I & \Aim
LEOPOLD-KUVIN.,
CONSUMER JUSTICE ATTORNEYS
January 4, 2010
Re: B.B.'. JEFFREY EPSTEIN
OUR FILE NO.: 080303
Dear Ms. Villafana:
After taking the deposition of Police Chief, it came to our attention that
apparently a computer which was initially seized during the search warrant conducted on Mr.
Epstein's home was returned by the FBI to a private investigator employed by Mr. Epstein. We
would like to determine who this computer was returned to, and when it was returned. It would
assist us greatly if you could check your records to determine when, and if, this was ever done.
Additionally, according to the sworn testimony of Chief Reiter, his department was provided
with a letter containing a list of potential victims of Mr. Epstein. This letter contained language
pursuant to a previously unknown Federal Statute which apparently directed him to destroy the
letter after reading it. We hereby request that your office advise what Statute or Code that letter
was referring to. Finally, we would like to schedule the depositions of cm oraa:ai Au—
ONINNIMINININONSIMPINISIIIIMISION. Please let me know who we need to direct
our subpoenas to in order to schedule these depositions.
I appreciate your immediate attention to this matter. Should you have any additional questions
about these issues, please do not hesitate to contact me at once.
STK:mlb
2925 PGA Boulevard Suite 200 Palm Beach Gardens - Florida 33410 .. 581.515.1400 fax 581.515.1401 leopolthuvin.com
CRASHWORTHINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
EFTA00207019
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Original Transcript
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
MARK EPSTEIN
September 21, 2009
11:30 a.m.
One Penn Plaza,
New York. New York
Jacklyn Lisi
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
SlS East Las Olas Boulevard
ESQUIRE Fort Lauderdale, FL 33301
wvinv.esquIresoludons.com
EFTA00181510
•
•
•
EFTA00181511
1
• UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff,
vs. Case No. 08-80893-
CIV-MARRA/JOHNSON
JEFFREY EPSTEIN,
Defendant.
DEPOSITION of MARK EPSTEIN, taken by
• Defendants, at the offices of Esquire Deposition Solutions,
One Penn Plaza, New York, New York 10119, on Monday,
September 21, 2009, commencing at 11:30 a.m., before Jacklyn
Lisi, a Shorthand Reporter and notary public, within and for
the State of New York.
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
vnvw.esquiresoludons.com
EFTA00181512
Mark Epstein September 21, 2009
2
1 APPEARANCES :
2 ROTHSTEIN ROSENFELDT ADLER, ESQS.
Attorneys for Plaintiffs, EW, LM and Jane Doe
3 Las Olas City Centre, Suite 1650
401 East Las Olas Boulevard
4 Fort Lauderdale, Florida 33301
5 BY: BRAD J. EDWARDS, ESQ.
6
7 LEOPOLD KUVIN, ET AL
Attorneys for Plaintiff, BB
8 2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
9
BY: ADAM LANGINO, ESQ.
10 (via telephone)
11
COHEN & GRESSER, LLP
12 Attorneys for the Witness, Mark Epstein
100 Park Avenue
13 New York, New York 10017
14 BY: MARK S. COHEN, ESQ.
ALEXIS G. STONE, ESQ.
15
16
PODHURST ORSECK, et al
17 Attorneys for Plaintiffs, Jane Does 101 and 102
25 West Flagler Street, Suite 800
18 Miami, Florida 33130
19 BY: KATHERINE EZELL, ESQ.
(via telephone)
20
21
MERMELSTEIN & HOROWITZ, ESQS.
22 Attorneys for Plaintiffs, Jane Does 2 through 8
18205 Biscayne Boulevard, Suite 2218
23 Miami, Florida 33160
24 BY: ADAM H. HOROWITZ, ESQ.
(via telephone)
25
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181513
Mark Epstein September 21, 2009
3
• 1
2
APPEARANCES (continued)
RICHARD H. WILLITS, ESQ.
3 Attorney for Plaintiff,
2290 10th Avenue North, Suite 404
4 Lake Worth, Florida 33461
(via telephone)
5
6 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
Attorneys for the Defendant, Jeffrey Epstein
7 515 North Flagler Drive, Suite 400
West Palm Beach, Florida 33401
8
BY: ROBERT CRITTON, ESQ.
9 (via telephone)
10
* * *
• 11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181514
Mark Epstein September 21, 2009
4
1 STIPULATIONS
2
3 IT IS HEREBY STIPULATED, by and between the attorneys
4 for the respective parties hereto, that all rights provided
5 by the C.P.L.R., and Part 221 of the Uniform Rules for the
6 Conduct of Depositions, including the right to object to any
7 question, except as to form, or to move to strike any
8 testimony at this examination is reserved; and in addition,
9 the failure to object to any question or to move to strike
10 any testimony at this examination shall not be a bar or
11 waiver to make such motion at, and is reserved to, the trial
12 of this action.
13 This deposition may be sworn to by the witness being
14 examined before a Notary Public other than the Notary Public
15 before whom this examination was begun, but the failure to
16 do so or to return the original of this deposition to
17 counsel, shall not be deemed a waiver of the rights provided
18 by Rule 3116 of the C.P.L.R. and shall be controlled
19 thereby.
20 The filing of the original of this deposition is
21 waived.
22
23
24
25
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181515
Mark Epstein September 21, 2009
5
• 1
2
M. Epstein
THE REPORTER: Please state your name
3 and address for the record?
4 THE WITNESS: (Witness refused to give
5 his address to the court reporter.)
6 MR. COHEN: On the record.
7 For the witness, Mark Epstein, Mark
8 Cohen and Alexis Stone of Cohen & Gresser, 100
9 Park Avenue, New York, New York.
10 MR. EDWARDS: Brad Edwards on behalf
11 of EW, LM and Jane Doe.
12 MR. CRITTON: Robert Critton on
13 behalf of Jeffrey Epstein.
• 14
MS. EZELL: Kathy Ezell on behalf of
15 Jane Does 101 and 102
16 MR. HOROWITZ: Adam Horowitz on
17 behalf of Plaintiffs, Jane Does 2 through 8.
18 MR. WILLITS: Richard Willits on
19 behalf of
20 MR. LANGINO: Adam Langino on behalf
21 of Plaintiff, BB.
22 MR. EDWARDS Okay. That's everybody.
23 MR. COHEN: Okay. Before I start,
24 this is Mark Cohen on behalf of Mark Epstein,
25 I just want to put on the record the details
• CI Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutlons.com
EFTA00181516
Mark Epstein September 21, 2009
6
1 M. Epstein
2 of a conversation I've had with Mr. Edwards
3 and make sure that all counsel is agreeable to
4 this.
5 My client, Mark Epstein, is very
6 concerned about being videotaped and having
7 his image recorded.
8 He is concerned about possible future
9 uses of his image. And so Mr. Edwards and I
10 have agreed that this recording, the videotape
11 of my client, will be confidential and will
12 not be revealed in public unless and until
13 there is an order by a court in one of the
14 cases that are involved in these depositions
15 that orders that the video be made public.
16 We are prepared to proceed on that
17 basis.
18 As I understand, Mr. Edwards is
19 prepared to proceed, but obviously we need the
20 agreement of all counsel.
21 MR. WILLITS: Richard Willits agrees.
22 MR. CRITTON: Robert Critton agrees.
23 MS. EZELL: Kathy Ezell agrees.
24 MR. EDWARDS: Adam?
25 MR. HOROWITZ: Adam Horowitz, that's
Toll Free: 800.211.3376
0 Facsimile: 954.331.4418
Suite 1300
ESQUIRE so M n&44 Oa la Ces7a7
515 East Las olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181517
Mark Epstein September 21, 2009
7
• 1
2 fine.
M. Epstein
3 MR. LANGINO: The same with Adam
4 Langino, that's fine.
5 MR. COHEN: All right. Thank you.
6 MR. EDWARDS And Sid Garcia is not in
7 and he is not supposed to be in; right?
8 MR. CRITTON: This is Bob Critton.
9 I assume -- I don't know whether he
10 was going to come or not, but I assume that
11 everyone will also abide and not give Mr.
12 Garcia a copy of the video until he also
13 affirms in writing to Mr. Cohen that he's
• 14
15
agreed to be bound by the same agreement.
MR. EDWARDS: Okay.
16 THE VIDEOGRAPHER: This is tape
17 number one to the videotape deposition of Mark
18 Epstein in the matter of Jane Doe versus
19 Jeffrey Epstein being held before the United
20 States District Court in the Southern District
21 of Florida, case file number 08-80893.
22 This deposition is being held at
23 Esquire Deposition Solutions, One Penn Plaza,
24 New York, New York on September 21, 2009. The
25 time is 11:41 a.m.
Toll Free: 800.211.3376
• 0 Facsimile: 954.331.4418
ESQUIRE
Suite 1300
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181518
Mark Epstein September 21, 2009
8
1 M. Epstein
2 My name is Peter Ledwith. I'm the
3 videographer. The court reporter is Jackie
4 Lisi.
5 Counsel, will you please introduce
6 yourselves and who you represent?
7 MR. EDWARDS: Brad Edwards. I
8 represent EW, LM and Jane Doe.
9 MR. COHEN: Mark Cohen and Ally
10 Stone. I represent the witness, Mark Epstein.
11 MR. CRITTON: Robert Critton on
12 behalf of the defendant, Jeff Epstein.
13 MR. WILLITS: Richard Willits on
14 behalf of
15 MR. LANGINO: Adam Langino on behalf
16 of Plaintiff BB.
17 MR. HOROWITZ: Adam Horowitz on
18 behalf of plaintiffs Jane Does numbers 2
19 through 8.
20 THE VIDEOGRAPHER: Will the court
21 reporter please swear in the witness?
22 MARK EPSTEIN,
23 having been first duly affirmed, was examined
24 and testified as follows:
25 THE WITNESS: I am an atheist, but I
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE as Al and. GillsCaspar
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181519
Mark Epstein September 21, 2009
9
Si M. Epstein
2 will affirm I'll tell the truth.
3 EXAMINATION BY
4 MR. EDWARDS:
5 Q. Can you tell us your name?
6 A. Mark Epstein.
7 THE VIDEOGRAPHER: Can you put the
8 microphone on your shirt, please?
9 THE WITNESS: Mark Epstein.
10 Q. Okay. And your date of birth,
11 please?
12 A. July 14, 1954.
13 Q. And what is your relationship with
• 14 the defendant in this case, Jeffrey Epstein?
15 A. He is my brother.
16 Q. Are you currently married?
17 A. No.
18 Q. What is your current address?
19 A. I'm not giving out my address. I'm
20 concerned about my personal safety because of
21 the nature of this case. You can use his
22 address. You can use my attorney's address.
23 Q. Please elaborate on that for me that
24 you are concerned for your safety because of
25 the nature of this case?
Toll Free: 800.211.3376
II 0 Facsimile: 954.331.4418
Suite 1300
ESQUIRE
"......."
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181520
Mark Epstein September 21, 2009
10
1 M. Epstein
2 A. Because I've read -- well, I know
3 that Jeffrey hired a detective or someone from
4 the police when he went out on his days out.
5 So obviously there is probably a concern for
6 safety.
7 I don't want anything to do with this
8 case. I have nothing to do with this case.
9 don't want my identifying information on any
10 kind of public record.
11 MR. COHEN: If it will make it
12 easier, Mr. Edwards, this is Mark Cohen
13 speaking. Mr. Mark Epstein is authorizing my
14 firm to accept service if there is a future
15 subpoena or a need to contact him again.
16 THE WITNESS: Before we go on, I want
17 to make a statement.
18 I want to say on the record that
19 initially I was improperly served with a
20 subpoena from Florida, it was supposed to come
21 from New York.
22 It also did not include the required
23 documents giving me my rights and obligations
24 under the Florida laws. So it's a breach of
25 some kind of ethics.
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquIresolutIons.com
EFTA00181521
Mark Epstein September 21, 2009
11
• 1
2
M. Epstein
So in my book, you are either
3 incompetent, devious or have no ethical
4 compass.
5 So you are not on my high list.
6 Continue with your questions. I just wanted a
7 record of that.
8 MR. CRITTON: Brad, can you move the
9 phone a little closer to Mr. Epstein? I heard
10 you and I heard Mr. Cohen fine, but I'm having
11 trouble with Mr. Epstein.
12 MR. EDWARDS: All right.
13 MR. CRITTON: Thank you.
• 14
15
MR. EDWARDS: I apologize for your
feelings about the subpoena.
16 THE WITNESS: Not accepted.
17 This is too serious of a matter.
18 BY MR. EDWARDS:
19 Q. You do realize that you are
20 subpoenaed to testify today in cases that
21 involve your brother having sex or engaging in
22 sex acts with minors; correct?
23 MR. CRITTON: Form?
24 MR. COHEN: That's --
25 A. I know there is a case against my
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181522
Mark Epstein September 21, 2009
12
1 M. Epstein
2 brother. I know that.
3 Q. And you are aware that there are
4 multiple attorneys on the phone that represent
5 girls who were under-age when Mr. Epstein had
6 sex with them?
7 A. I know there are multiple attorneys
8 on the phone.
9 Q. Okay. Have you read the newspaper
10 articles about your brother that detail your
11 brother having sex with under-age girls?
12 MR. CRITTON: Form.
13 A. I've read some of the papers.
14 Q. You agree that sex with minors is
15 wrong?
16 MR. CRITTON: Form.
17 MR. COHEN: Objection.
18 Q. You can answer.
19 A. I have no opinion on that.
20 Q. Okay.
21 A. I'm not here to give opinions. I'm
22 here for facts. So ask me questions about
23 facts and I'll be glad to answer them.
24 Q. Well, do you agree with the laws that
25 protect under-age children from adult sexual
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE nAli 200loCal.fl
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutIons.com
EFTA00181523
Mark Epstein September 21, 2009
13
• 1
2 predators?
M. Epstein
3 MR. COHEN: Objection.
4 MR. CRITTON: Form.
5 A. My information on the case is my
6 brother I know had to spend sometime in jail
7 for some prostitution charge.
8 So I assume the attorneys are
9 representing the prostitutes he was involved
10 with, so I don't know what the ages of them
11 are or were.
12 I'm not involved with the case. I
13 don't watch all the details about it. That's
• 14
15
all.
Q. Would it surprise you to learn that
16 there were more than 30 girls between the ages
17 of 12 and 15 that your brother engaged in sex
18 acts with?
19 MR. CRITTON: Form.
20 A. I don't get surprised by very many
21 things in this world.
22 Q. But you and your brother are a year
23 apart; right?
24 A. 18 months.
25 Q. And you grew up together?
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutIons.com
EFTA00181524
Mark Epstein September 21, 2009
14
1 M. Epstein
2 A. Sure.
3 Q. You still talk to him?
4 A. Occasionally, rarely.
5 Q. So when I ask you, does it surprise
6 you, you are saying that it doesn't surprise
7 you that your older brother engaged in sex
8 with more than 30 girls between 12 and
9 15 years old?
10 MR. COHEN: Objection.
11 MR. CRITTON: Form.
12 A. I don't know how to answer that
13 question. I don't know if it's true, and I
14 don't know what the story is.
15 It's not -- ask me a question about
16 facts. I'm not going to give you opinions
17 here, that's not what I'm here for.
18 Q. Do you have children?
19 A. Yes, I do.
20 Q. How old?
21 A. Seven and five.
22 Q. Boys or girls?
23 A. What does my children have to do with
24 this? Leave my family out of this, please.
25 Q. I think it's a fair question.
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE a Al an4E; O.11a Lonny
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esguiresolutions.com
EFTA00181525
Mark Epstein September 21, 2009
15
• 1
2 A.
M. Epstein
I think it's a fair answer.
3 Q. I need an answer.
4 A. You got one.
5 Q. Boys or girls?
6 A. Next question.
7 MR. EDWARDS: Counsel?
8 MR. COHEN: I would suggest you move
9 to an area that's likely to lead to you
10 gathering relevant evidence.
11 We can come back to this burning
12 question maybe later.
13 MR. CRITTON: Let me also add that I
• 14
15
can only object to form, but I also want to
put on the record, other than his name and he
16 is related to Mr. Epstein, there is not one
17 piece of evidence or --
18 THE COURT REPORTER: I can't hear
19 you.
20 MR. CRITTON: I'm sorry. I just want
21 to note for the record that other than his
22 name and his relationship to Mr. Epstein, to
23 Jeffrey Epstein, there has been nothing of
24 relevance or materiality that would lead to
25 admissible evidence at the time of trial.
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
vnwv.esquiresolutIons.com
EFTA00181526
Mark Epstein September 21, 2009
16
1 M. Epstein
2 This is being done to harass or
3 humiliate Mr. Mark Epstein and/or my client.
4 It certainly borders on that, but he is not an
5 expert, his opinions are irrelevant in this
6 case, and as is his own family situation
7 but --
8 MR. EDWARDS: Mr. Critton, as you
9 stated first, I think that your objection is
10 limited to the form. Thanks.
11 Can I mark this as an exhibit?
12 (Plaintiff's Exhibit 1 was so marked
13 for identification.)
14 MR. COHEN: I will say that I join in
15 Mr. Critton's objection for the record.
16 BY MR. EDWARDS:
17 Q. How frequently do you talk with your
18 brother now?
19 A. Maybe once every couple of weeks or
20 so, but "now" being just the last month or
21 two.
22 Q. Okay. When you first learned of a
23 criminal investigation into your brother, did
24 you talk to him about the substance of those
25 allegations?
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, Fl. 33301
www.esquiresolutIons.com
EFTA00181527
Mark Epstein September 21, 2009
17
•1 M. Epstein
2 A. No.
3 Q. Have you ever asked him or had a
4 conversation with him about the allegations
5 that he's had sex with numerous under-age
6 kids?
7 A. No.
8 Q. Is there a reason why you wouldn't
9 ask him questions about him engaging in sex
10 with 13, 14-year old kids?
11 A. We are not very close. We don't talk
12 very often.
13 MR. CRITTON: Form.
• 14
15
Q. But when you do talk to him, that
conversation doesn't come up?
16 A. No.
17 Q. He went to jail. Did he ever tell
18 you why he went to jail?
19 A. No.
20 Q. Are you familiar with the property at
21 301 East 66th Street?
22 A. Yes, I am.
23 Q. Who owns that property?
24 A. Dara Partners.
25 Q. And what is Jeffrey Epstein's
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181528
Mark Epstein September 21, 2009
18
1 M. Epstein
2 affiliation with that property?
3 A. He rents some apartments in there.
4 Q. How many apartments does Jeffrey
5 Epstein rent at 301 East 66th Street?
6 A. It's either 8 or 10, I am not sure.
7 Q. Who are the residents of the
8 apartments that Jeffrey Epstein rents at that
9 location?
10 A. I have no idea.
11 MR. CRITTON: Brad, what was the
12 answer to the last one?
13 MR. COHEN: He has no idea.
14 A. I know his pilots used to stay there,
15 but I don't think he is using pilots any more.
16 Q. Why does he rent so many places at
17 the same location?
18 A. I have no idea.
19 Q. Have you ever had any affiliation
20 with that location?
21 A. Sure.
22 Q. In what way?
23 A. I'm one of the partners of Dara
24 Partners.
25 Q. So does your brother rent from you?
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE nM aaaa
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181529
Mark Epstein September 21, 2009
19
• 1
2 A.
M. Epstein
No, he rents from Dara Partners. My
3 partner handles that property, I don't know
4 any of the tenants in that building other than
5 one or two.
6 Q. What are the names of the one or two
7 that you do know?
8 A. It is my ex, so I'm not going to give
9 you her name.
10 Q. Is that somebody who lives in one of
11 the places rented by your brother Jeffrey
12 Epstein?
13 A. No.
• 14 Q. Do you know any of the tenants that
15 live in the places rented by your brother,
16 Jeffrey Epstein?
17 A. No.
18 Q. Do you know ?
19 A. I know the name. I don't know her.
20 Q. Do you know what her relationship is
21 to your brother?
22 A. I think she worked for him.
23 Q. In what capacity?
24 A. I have no idea.
25 Q. Do you know if she lives in 301 East
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
ESQUIRE
Suite 1300
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquIresolutlons.com
EFTA00181530
Mark Epstein September 21, 2009
20
1 M. Epstein
2 66th Street?
3 A. I don't know where she lives.
4 Q. Would you know her if you saw her?
5 A. No.
6 Q. You've never seen her before?
7 A. I might have seen her somewhere, I
8 don't know.
9 Q. Have you ever talked to her?
10 A. I don't recall talking to her.
11 Q. Do you know
12 A. I know of her.
13 Q. How do you know of her?
14 A. In the papers.
15 Q. What papers?
16 A. Newspapers. I read some articles.
17 Q. Newspapers about your brother?
18 A. Relating to his case, yes.
19 Q. Okay. And what is your understanding
20 of her relationship with your brother?
21 A. I don't have an understanding about
22 it.
23 MR. CRITTON: Form.
24 A. My brother and I do not have a close
25 relationship, so what he does is his business
Toll Free: 800.211.3376
Facsimile: 954.331.4418
ESQUIRE Suite 1300
515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181531
Mark Epstein September 21, 2009
21
M. Epstein
2 and what I do is my business.
3 We don't communicate back and forth
4 about our personal lives very often. I talk
5 to him to find out if he is well. That's all
6 I need to know.
7 Q. Does he tell you that he is well
8 these days?
9 A. Yes.
10 Q. Do you know what his future plans are
11 in terms of where he intends to live once he
12 is off probation or house arrest?
13 A. I have no idea.
• 14
15
Q. Is that a topic that you would ever
talk to him about?
16 A. No.
17 Q. So what is it that you talk to him
18 about when you call?
19 A. See how he is doing, see if he is
20 okay.
21 Q. Does he call you as well?
22 A. Sometimes.
23 Q. What is his telephone number?
24 A. Where?
25 Q. What are the telephone numbers that
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, Fl. 33301
www.esquiresolutions.com
EFTA00181532
Mark Epstein September 21, 2009
22
1 M. Epstein
2 you reach him at?
3 A. A lot of times I call his office and
4 I have them tell him to call me.
5 Q. What is his office number?
6 A.
7 Q. Who do you speak to at his office?
8 A. Whoever answers the phone.
9 Q. Do you know any of the people in his
10 office that typically answer the phone?
11 A. Some.
12 Q. Who are you familiar with there?
13 A. Darren. An attorney, Darren.
14 Q. Darren Indyke?
15 A. Yes.
16 Q. So normally the way that you get in
17 touch with your brother is to call his office
18 and they forward you on to him?
19 A. No, I tell them to have him call me.
20 Well, sometimes, I mean I've called him
21 directly too, but most of the time he is not
22 there so it's easier just to leave a message
23 to have him call me.
24 Q. Well, these days now that he is on
25 house arrest, normally if you called him he'd
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquIresolutions.com
EFTA00181533
Mark Epstein September 21, 2009
23
M. Epstein
be there, right?
A. I don't know the term house arrest.
I don't know if he'd be there or not. And if
I called there and sometimes he doesn't answer
or the phone doesn't get answered, so I don't
know where he is.
Q. What's the number that you would call
to reach him?
10 A.
11 Q. Is it your understanding that is a
12 cell phone or is that the land line?
13 A. I thought it was a land line.
• 14 Q. And what is your telephone number?
15 A. I'm not giving you any identifying
16 information.
17 MR. EDWARDS: We can come back to
18 that?
19 MR. COHEN: Why don't we come back to
20 that.
21 MR. EDWARDS: Okay.
22 Q. Are you familiar with your brother's
23 businesses?
24 A. No.
25 Q. Do you know a person by the name of
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
mr4w.esquIreSolutIons.com
EFTA00181534
Mark Epstein September 21, 2009
24
1 M. Epstein
2 Jean Luc Brunel?
3 A. No.
4 Q. How often are you at the property at
5 301 East 66th Street?
6 A. I pick up my children there
7 sometimes. Maybe -- well, actually, they are
8 in school now so I'm not there that often,
9 because I pick them up at school.
10 During the summers I would pick them
11 up there once a week.
12 Q. Is that where the subpoena was served
13 on you?
14 A. No, the subpoena was served on me in
15 the street of New York.
16 Q. Near that building?
17 A. No.
18 Q. No where near that building?
19 A. It was in The City of New York, it
20 depends on what you mean by "near."
21 Q. Have you been to your brother's house
22 in New York?
23 A. Yes.
24 Q. How many occasions?
25 A. Under five.
Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181535
Mark Epstein September 21, 2009
25
•1 M. Epstein
2 Q. Have you been to your brother's house
3 in Palm Beach?
4 A. When.
5 Q. Ever?
6 A. Yes.
7 Q. How many occasions?
8 A. Probably dozens.
9 Q. When is the last time you were there?
10 A. Probably about a decade ago. I was
11 outside once more recently than that.
12 During one of the hurricanes, he
13 asked me to take a look at the property, but I
• 14
15
did not go in.
Q. Why not?
16 A. There was no inside damage. I went
17 to see the property just to see if there was
18 damage to the property. I was in Florida at
19 the time.
20 Q. Why has it been more than 10 years
21 since you've been to that property?
22 A. My brother and I are not very close.
23 Q. What is the reason why you are not
24 very close?
25 A. We just went our own ways.
• 0 Toll Free: 800.211.3376
Facsimile: 954.331.4418
Suite 1300
ESQUIRE 515 East Las Olas Boulevard
Fort Lauderdale, FL 33301
www.esquiresolutions.com
EFTA00181536
Mark Epstein September 21, 2009
26
1 M. Epstein
2 Q. Does it have to do with the fact that
3 he likes under-age girls and engages in that
4 type of illegal activity?
5 MR. COHEN: Objection.
6 MR. CRITTON: Form.
7 A. I'm not going to make that
8 assumption, but it has nothing do with
9 anything like that. We just went our own
10 ways. Different interests, different things.
11 Q. Knowing your brother, if
DataSet-9
Unknown
1 pages
From: Jean Luc Brunel
To: "jeevacation®gmail.com"
Subject: Yo
Date: Thu, 27 Sep 2012 00:37:17 +0000
If you have any news about Opium group.please let me know
I have a question about. deposition
An advice...I want to ask how to focus on the right point etc...
EFTA00944758
DataSet-9
Unknown
2 pages
From: Jean Luc Brunel
To: Jeffrey Epstein
Subject: Re: C.L. v. Epstein - Notice of Deposition of in Miami
Date: Thu, 22 Apr 2010 08:53:01 +0000
Inline-Images: image.png
Cannot open
On 4/21/10 5:15 PM, "Jeffrey Epstein" wrote:
Sent from my iPhone
Begin forwarded message:
From: "Connie Zaguirre, CP, FRP" <
Date: April 21, 2010 5:17:22 PM EDT
To: <[email protected]>, "Darren Indyke" <
Subject: C.L. v. Epstein - Notice of Deposition of
in Miami
Enclosed please find Plaintiff's Notice of Deposition of
on 5/18/10 in Miami.
Connie Zaguirre, CP, FRP - Assistant for Robert D. Critton, Jr.
I
Phone: I Fax•
> I www.bciclaw.com
This e-mail contains legally privileged and confidential information
intended only for the individual or entity named within the message.
Should the intended recipient forward this message to another person or
party, that action could constitute a waiver of the attorney/client
privilege. If the reader of this message is not the intended recipient,
or the agent responsible to deliver it to the intended recipient, you are
hereby notified that any review, dissemination, distribution or copying
of this communication is prohibited. If this communications was received
in error, please notify us by reply e-mail and delete the original
message.
EFTA00760307
EFTA00760308
DataSet-9
Unknown
227 pages
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 50200BCA028051XXXXMB AD
Plaintiff,
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF LARRY VISOSKI
Thursday, October 15, 2009
10:18 - 3:37 p.m.
515 N. Flagler Drive
Suite P200
West Palm Beach, Florida 33401
Reported By:
Wendy Beath Anderson, RPR, CRR, FPR
Notary Public, State of Florida
Esquire Deposition Services
West Palm Beach Office Job 8127542
3527-003
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Larry Visoski October 15, 2009
2
1 APPEARANCES:
2 On behalf of the Plaintiff:
3 BRADLEY J. EDWARDS, ESQUIRE
ROTHSTEIN, ROSENFELDT, ADLER
4 401 East Las Olas Boulevard
Suite 1650
5 Fort Lauderdale, Florida 33394
6
7 On behalf of the Defendant:
8 ROBERT D. CRITTON, JR., ESQUIRE
BURMAN, CRITTON & LUTTIER
9 303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
10
11 On behalf of the Witness:
12 BRUCE REINHART, ESQUIRE
250 South Australian Avenue
13 Suite 1400
West Palm Beach, Florida 33401
14
15 ALSO PRESENT:
16 CARA L. HOLMES, ESQUIRE
1220 N.W. 157th Avenue
17 Pembroke Pines, Florida 33028
18 ADAM D. HOROWITZ, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
19 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
20
RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE)
21 RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
22 Lake Worth, Florida 33461
23
24
25
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Larry Visoski October 15, 2009
3
1
2 I NDEX
3
4
5 WITNESS: DIRECT CROSS REDIRECT RECROSS
6
LARRY VISOSKI
7
BY MR. EDWARDS: 6
8 BY MR. CRITTON: 214
BY MR. EDWARDS: 220
9 BY MR. CRITTON: 221
10
11
12
13 EXH IB ITS
14
15
16 NUMBER DESCRIPTION PAGE
17 PLAINTIFF'S EX. 1 FLIGHT LOG BOOK
(MARKED IN PREVIOUS DEPO)
18
19 PLAINTIFF'S 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
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Larry Visoski October 15, 2009
4
1 PROCEED I NGS
2
3 Deposition taken before Wendy Beath Anderson,
4 Certified Realtime Reporter and Notary Public in and for
5 the State of Florida at Large, in the above cause.
6 - - -
7 MR. EDWARDS: We're going to put something on
8 the record about -- well, we'll do it this way --
9 MR. REINHART: Do it at the end, after we get
10 him -- whatever you want. It's your show
11 MR. EDWARDS: Okay. There were don't
12 even think Mr. Willits is aware of this. There was
13 a subpoena duces tecum for this witness, as well as
14 the previous witness, which was another pilot, Dave
15 Rogers, and that duces tecum was to bring the
16 flight logs related from 1998 through 2005. What
17 was produced at the previous deposition were flight
18 logs from 2002 through 2005, and now Mr. Reinhart
19 has agreed to produce the remainder of the flight
20 logs requested, those going from 1998 through 2002.
21 MR. REINHART: Correct. They're pilot logs,
22 not flight logs. There are other records we
23 indicated are corporate records, and with those you
24 have to deal with Mr. Critton.
25 MR. CRITTON: However, with the proviso, too,
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Larry Visoski October 15, 2009
5
1 that we're going to work out that these records are
2 to be used within the confines of this litigation
3 and not to be spread to the press or anyone else,
4 because they do contain confidential information as
5 to who may have been on the plane and other records
6 of Mr. Rogers, which but for the subpoena would
7 have been only available to the FAA or some other
8 law enforcement agencies.
9 MR. EDWARDS: Okay. Is that all you want to
10 put on?
11 MR. CRITTON: Yes.
12 MR. EDWARDS: I'm not saying I necessarily
13 agree or disagree with you. That's something that
14 we'll deal with some other day.
15 MR. CRITTON: Bruce, you'd better produce
16 these records, but there has to be some sort of
17 understanding before --
18 MR. REINHART: Correct.
19 MR. EDWARDS: I won't do anything until you
20 file whatever you until we work whatever it is
21 out in court. I'll say that on the record, that
22 I'm not doing anything with the records outside of
23 my office until some judge deals with it.
24 MR. REINHART: And for the record, I'll adopt
25 what Mr. Critton said on this one limited occasion.
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Larry Visoski October 15, 2009
6
1 MR. EDWARDS: All right.
2 Thereupon,
3 (LARRY VISOSKI)
4 having been first duly sworn or affirmed, was examined
5 and testified as follows:
6 THE WITNESS: Yes, I do.
7 DIRECT EXAMINATION
8 BY MR. EDWARDS:
9 Q. Can you tell us your name for the record.
10 A. Lawrence Visoski, Jr.
11 Q. And Mr. Visoski, have you ever had your
12 deposition taken before?
13 A. No.
14 Q. Okay. Here's the process: I'm going to ask
15 you questions. You're going to give us answers. Try to
16 give us answers that we all understand and that the
17 court reporter can take down, such as yes, no, or some
18 other verbal answer that we can understand. It's easy
19 when we get in a casual conversation to nod or shake
20 your head, and the court reporter is not writing
21 pictures or anything else.
22 A. I understand.
23 Q. The other thing is, and I've been accused of
24 this in other depositions -- I don't know if it's true
25 or not -- but I need to wait until you finish answering
3527-003
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Larry Visoski October 15, 2009
7
1 the question and you need to wait until I finish asking
2 the question.
3 A. So you're not allowed to interrupt me?
4 Q. And you're not allowed to interrupt me.
5 A. Like I just did?
6 Q. Right.
7 MR. CRITTON: Cara just snickered when you
8 said you've been accused because she recognizes
9 it's true.
10 MR. EDWARDS: I don't know what the meaning of
11 her snickering was.
12 BY MR. EDWARDS:
13 Q. But for what it's worth, if you don't
14 understand the question or I've asked a bad question, I
15 don't want you to guess. Give me the best answer to the
16 best of your knowledge and if you need me to rephrase
17 it, I will.
18 A. Okay.
19 Q. Okay. Tell me your current address.
20 A.
22 Q. How long have you lived there?
23 A. Approximately nine years.
24 Q. Okay. Who do you live there with?
25 A.
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Larry Visoski October 15, 2009
8
1 Q.
2 A.
3
4
S
10 Q• Who's your employer right now?
11 A. NES, LLC.
12 Q. How long has NES, LLC been your employer?
13 A. I'm guessing. I'd say back 1991. I have to
14 do the math, but 17, 18 years.
15 Q. Has that been your only employer since 1991?
16 A. Yes.
17 Q. And has that been your only source of income
18 since 1991?
19 A. Yes.
20 Q. And what is NES, LLC?
21 A. I don't really know. I mean, it's the company
22 that my check comes from.
23 Q. What do you do for NES, LLC that results in
24 them paying you?
25 A. I am chief pilot for the aircraft and
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Larry Visoski October 15, 2009
9
1 helicopters.
2 Q. And do you have a specific boss or somebody
3 you answer to at NES, LLC?
4 A. Several people would call to schedule flights
5 from the office, being it either Mr. Epstein or, you
6 depositions that there are also apartments in that
building?
4 A. Yes.
5 Q. And Mr. Epstein either owns or leases or rents
6 certain of those apartments. Is that your
7 understanding?
MR. CRITTON: Form; speculation.
9 THE WITNESS: I'm only speculating. I
10 don't -- to my understanding, I don't know.
11 BY MR. EDWARDS:
12 Q. Do you know other people that live in that
13 building?
14 A. Well, it would be myself, Dave Rogers -- well,
15 when you say "live,' explain.
16 Q. When you're saying yourself and Dave Rogers --
17 A. See, we don't live there. I mean, we have --
18 we would stay there when we would have a trip.
19 Q. Okay. When you would fly up to New York and
20 land in New York, the place where you would stay, is
21 that
22 A. Yes, that's correct.
23 Q. That's also a location you've indicated in
24 this deposition that is the office for NES, LLC?
25 A. Yes.
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Larry Visoski October 15, 2009
11
1 Q. What floor or suite number is NES, LLC in?
2 A. I believe -- well, I don't know that NES, LLC
3 has an office there. I know that's where Leslie has the
4 phone number where I call. So I don't know for a fact
S If NES, LLC has an office there.
6 Q. And what suite number, then, would Leslie
:ruff sit in to answer that telephone number at
8
9 A. I think it's III.
10 Q. And when you stay at
11 what suite number or what apartment number do you stay
12 in?
13 A.
14 Q. And how about Dave Rogers, where does he stay?
15 A. I'm guessing, because it's been some time
16 since we've been there, 10B, but don't quote me on it.
17 Q. Who are the other people in that building that
18 you know to stay there on a regular -- fairly regular
19 basis?
20 A. I've seen people in the elevator that, you
21 know, have been on the airplane. Case in point, maybe
22 -• but I don't know for a fact that she lives
23 there, or anybody else for that matter.
24 Q. Okay. When you say you've seen
25 on the elevator --
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Larry Visoski October 15, 2009
12
1 A. I only assume she lives there. I don't know
2 .or a fact. I'm trying to be honest and factual for
3 So I couldn't honestly say if I knew she lived
4 - here or not.
5 O. Where do you think lives?
6 A. I would think she lives there.
7 Q. You don't have a better location?
8 A. I don't have another location.
9 Q. Anybody else?
10 A. Not to my knowledge. I mean, I'd only be
11 guessing that people live in that building that -- you
12 know, I don't have any facts to prove that they actually
13 live there. I mean, I don't think you want me to guess.
14 Q. Well, NES, LLC, would you say that the owner
15 or controller of that company is Jeffrey Epstein?
16 MR. CRITTON: Form.
17 THE WITNESS: I don't know that for a fact.
18 BY MR. EDWARDS:
19 Q. Jeffrey Epstein is somebody you've indicated
20 that you've worked for for 17 or 18 years, right?
21 A. Yes.
22 Q. And over the 17 or 18 years you've become
23 personally close with him as well, correct?
24 MR. CRITTON: Form.
25 THE WITNESS: I don't understand how you mean
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Larry Visoski October 15, 2009
13
1 •close." Define that.
2 BY MR. EDWARDS:
3 Q. Well, more so than just a pilot that takes him
4 from Point A to Point B?
A. That is my job.
6 Q. Right. But you know him on a personal level
7 and that you've had personal conversations that don't
8 necessarily deal with flying from Point A to Point B;
9 isn't that right?
10 MR. CRITTON: Form.
11 THE WITNESS: More specific, meaning we talk
12 about cars. I mean, does that make you a personal
13 friends?
14 BY MR. EDWARDS:
15 Q. Have you ever gone to his house to eat?
16 A. No.
17 Q. Have you been to his New York home?
18 A. Yes.
19 Q. How many occasions have you been to his New
20 York home?
21 MR. CRITTON: Object to form.
22 THE WITNESS: We normally pick up luggage in
23 the lobby, so it would probably be quite often.
24 Any time we depart out of New York, we stop by the
25 house and pick up luggage and head to the aircraft.
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Larry Visoski October 15, 2009
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1 BY MR. EDWARDS:
2 Q. Other than picking up luggage, have you been
3 to his home to visit or socialize with him?
4 A. Not to socialize, no.
5 Q. Have you been to his Palm Beach home?
6 A. To?
7 Q. To Mr. Epstein's Palm Beach house?
8 A. Right.
9 Q. Have you been there?
10 A. Yes.
11 Q. Have you been inside?
12 A. Yes.
13 Q. And how many occasions have you been inside
14 that home?
15 A. The same, as far as picking up luggage, and
16 that would be on a regular basis, you know, for a
17 Aeparture. We wouldn't always go to the house to pick
18 up luggage, but it made it easier for loading the
19 aircraft, getting it done prior to departure.
20 Q. Is that the only reason that you have ever
21 gone to the Palm Beach home over the last 18 years, is
22 to pick up luggage?
23 A. No.
24 Q. What other reasons have you gone there?
25 A. I've set up several home theater equipments,
3527-003
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EFTA_00009689
EFTA00159496
Larry Visoski October 15, 2009
15
you know, televisions and such.
2 Q. Is that another hobby or job or something of
3 yours?
4 A. Both.
5 Q. Does he pay you for that?
6 A. Not any more than my salary.
7 Q. What's your current salary?
8 A. At this time, 180,000.
9 Q. And what are you paid $180,000 to do?
10 A. To manage his aircraft.
11 Q. What does that entail?
12 A. Scheduling maintenance. Anything that has to
13 do with any flight, whether it be weather, flight
14 planning, time and distance to and from a location, any
15 logistics involved in running an operation that has
16 aircraft.
17 Q. In addition to the 180,000, does he give you
18 bonuses as well?
19 A. There have been Christmas bonuses.
20 Q. Over the years, you mean, there have been
21 Christmas bonuses?
22 A. Yes.
23 Q. Is 180,000 the most he's ever paid you?
24 A. No.
25 Q. All right. Were you making -- when was the
3527-003
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EFTA_00009690
EFTA00159497
Larry Visoski October 15, 2009
16
1 last time that you were making an amount different than
2 180,000?
3 A. Last year.
4 Q. That would be 2008?
5 A. That would be correct. Yeah, we all took a
6 salary cut, I don't know the exact date. It might have
7 been 2008, last year. It was last Christmas we all took
a 10 percent salary cut.
9 Q. Do you know why?
10 A. Economic reasons.
11 Q. And who told you that you were going to have
12 to take the salary cut?
13 A. Darren Indyke.
14 Q. And did you ask for an explanation?
15 A. He explained it was due to economic reasons
16 throughout the country.
17 Q. Okay. So in 2008, how much was -- were you
18 being paid by NES, LLC?
19 A. 200,000.
20 Q. And is 200,000 the most that you've ever made
21 from NES, LLC?
22 A. Yes, sir.
23 Q. And on top of that $200,000, did you get a
24 bonus that year as well?
25 MR. REINHART: Which year are you talking
3527-003
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EFTA_00009691
EFTA00159498
Larry Visoski October 15, 2009
17
1 about?
2 MR. EDWARDS: 2008.
3 THE WITNESS: That year, I think we skipped
4 Christmas bonuses that year. The last bonus might
5 have been 2007.
6 BY MR. EDWARDS:
7 Q. If you ever got a bonus from Mr. Epstein
8 and I'm only deriving this from you using the term
9 "Christmas bonus."
10 A. Holiday bonus.
11 Q. -- am I correct to assume sorry. Am I
12 correct to assume that if you got a bonus, there was
13 only one and it was at the end of the year, around the
14 holidays?
15 A. Yes.
16 Q. Okay. And how much was the 2007 holiday
17 bonus?
18 A. I'd have to ask my wife, to be honest. I
19 haven't seen my paycheck in 27 years, so I believe it
20 was $10,000.
21 Q. And in 2007 you also made $200,000?
22 A. Yes.
23 Q. Okay.
24 A. With a question mark. I'm trying to be as
25 accurate as I can, but yes.
3527-003
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EFFA_00009692
EFTA00159499
Larry Visoski October 15, 2009
18
1 Q. Something pretty close to that?
2 A. Yes, sir.
3 Q. Okay. So with the bonus it was 210,000,
4 roughly?
5 A. Right.
6 Q. Okay. And how long were you making that
7 salary?
8 A. Probably -- he was very religious about giving
9 annual increases, so I would probably say 2006, you
10 know, it was -- we would get increment -- increases of
11 five or $10,000 each year. So I would say 2006. So it
12 graduated, you know, progressive.
13 Q. Okay. Do you remember the progression if we
14 start at 1991? Do you remember roughly what the
15 progression was up through 2007/2008, when you were
16 making $200,000?
17 A. No, I wouldn't know the progression.
18 Q. Okay. Do you remember what you were making
19 from and was NES, LLC the company paying you back in
20 1991?
21 A. I don't know. I don't remember. Let me say
22 it that way. I don't remember.
23 Q. Okay. When -- how long do you remember NES,
24 LLC being the payer of your check?
25 A. Personally, two years, because I've never seen
3527-003
Page 18 of 227
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFFA_00009693
EFTA00159500
Larry Visoski October 15, 2009
19
1 my paycheck. So I don't even know what's written on the
2 top of it.
3 Q. That would be something that only your wife
4 would see, I'm assuming?
5 A. You're right, since she probably wouldn't know
6 the answer either, because she's looking at the right
7 column and not the top column.
8 Q. Right. When is the first time that you had
9 heard the name NES, LLC, that company?
10 A. Five, six years, and even questioned what it
11 stood for. And I think to this day I couldn't answer
12 that honestly, what it stands for.
13 Q. Okay. But it's your understanding that the
14 NES, LLC is paying you for the work that you do as a
15 pilot or maintain the planes for Jeffrey Epstein?
16 A. To my understanding, yes.
17 Q. And back in 1991, do you know if it was a
18 different company that was paying you or if it was
19 Jeffrey Epstein directly paying you?
20 A. I don't remember. I mean, I don't.
21 Q. Okay. Throughout your career with -- as a
22 pilot for Jeffrey Epstein, since 1991, has there ever
23 been a time when you believe you were paid directly from
24 Jeffrey Epstein personally versus some company?
25 A. Not to my knowledge, no.
3527-003
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EFTA_00009694
EFTA00159501
Larry Visoski October 15, 2009
20
1 Q. Okay. So whether it was NES, LLC or some
2 other company, it was all of a sudden a company name, to
3 the best of your knowledge?
4 A. Exactly, yes.
5 Q. And back in 1991, do you remember
6 approximately how much you were being paid that year?
7 A. Fifty-five or 60,000, is maybe what I started.
8 Q. Okay.
9 A. You're going back a long ways.
10 Q. Yes.
11 A. I'm trying.
12 Q. Your relationship goes back that far. That's
13 why I chose that year.
14 A. Right.
15 Q• Okay. Did you get bonuses even back that far?
16 A. Yes, sir.
17 Q. And do you remember what your bonuses were
18 approximately?
19 A. 5,000. I mean, that was kind of the -- the
20 starting point.
21 Q. Okay. In addition to monitary bonuses, were
22 - here ever gifts or any other type of compensation that
23 NES, LLC or Jeffrey Epstein provided you?
24 A. Yes.
25 Q. And is that over the span of the 18 years?
3527-003
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EFTA_00009695
EFTA00159502
Larry Visoski October 15, 2009
21
1 A. Yes.
2 Q. Okay. Tell me what some of those items are.
3 A. I remember one specifically was a pool heater.
4 Q. Excuse me?
5 A. A pool heater.
6 Q. When was that?
7 A. 1995-ish.
8 Q. Okay. Why did you get that?
9 A. I had built a pool and I didn't have a heater
10 and he kind of laughed at me saying, "How can you have a
11 pool without a heater?" So he says, "You ought to get a
12 heater.•
13 Q. Where were you when you had that conversation?
14 A. In the airplane.
15 O. How did he know that you had built a pool?
16 A. Just in general conversation.
17 Q. You were having a conversation with Jeffrey
18 Epstein?
19 A. Yes.
20 Q. And this is something that was happening on
21 the airplane, this conversation?
22 A. During the flight. Yeah, it would have been
23 like on cruise or something.
24 Q. Okay. When you say •during the flight," does
25 that --
3527-003
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EFTA_00009696
EFTA00159503
Larry Visoski October 15, 2009
22
1 A. Again, you're going back a long ways.
2 Q. I understand. We're talking about 1995 right
3 now.
4 A. Yes.
DataSet-10
Unknown
1 pages
To:
From: jeffrey E.
Sent Fri 9/9/2016 4:16:57 PM
Subject: Re: Janusz and Renato
Have renato come at 1.15
On Friday, 9 September 2016, wrote:
Renato will pick you up at 4pm from your deposition as 1 have Janusz going to the Miami
airport to meet Florence and the 3 designers at customs to help them with their luggage and
getting on to the next gate for their connecting flight. I told Janusz to get a cart to help with
the luggage and direct them to their next flight...
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacationagmail,com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA_R1_00575860
EFTA02044396
DataSet-9
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
on Thursday, September 3, 2009, at 10:00 a.m., at:
Esquire Court Reporters
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this jzgday of August, 2009 to all those on the
attached Service List.
1
EFTA00725586
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
Tel:
Fax:
Email:
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reporters
EFTA00725587
DataSet-9
Unknown
2 pages
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR PALM BEACH COUNTY CIVIL DIVISION
CASE NO.: 502009CA040800 AG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, etc., et at,
Defendant(s).
OMNIBUS ORDER IN REGARD TO UPDATE DEPOSITION OF THE PLAINTIFF
THIS CAUSE came before the Court upon various Motions in regard to the
Defendant, BRADLEY J. EDWARDS' request for update deposition of JEFFREY EPSTEIN,
as well as a Request to Produce served upon EDWARDS and Motions to Impose Sanctions
against JEFFREY EPSTEIN. The Court has heard argument and has reviewed the
pleadings and is otherwise fully advised in the premises. Based upon the foregoing, it is
CONSIDERED, ORDERED AND ADJUDGED as follows:
The Defendant shall be entitled to take an update deposition of the Plaintiff
in regard to the specific issues identified and more specifically relating to public
statements made by the Plaintiff regarding his criminal activity, testimony dealing with
any claim the Plaintiff has waived his Fifth Amendment rights and/or has otherwise lost
his Fifth Amendment rights. The Defendant EDWARDS' Motion to Compel and Impose
Sanctions for Failure to Attend the Deposition is denied. In regard to the Request to
Produce submitted to the Defendant EDWARDS by the Plaintiff under certificate of service
the 7th day of April, 2011, the Court recognizes that there is a difference between "fact
work product", "opinion work product", and "contention discovery". "Opinion work
product" is almost never discoverable, "fact work product" is discoverable under limited
circumstances, and, according to the most recent pronouncements from the Fourth
District, "contention discovery" is allowed. Therefore, the Defendant shall respond to the
EFTA00591506
Request to Produce and assert any privilege in a privilege log, including any work product
privileges. The Defendant may do so in a manner which will not divulge or otherwise
disclose the nature of the documentation itself and if the parties cannot agree, the
documents shall be submitted to the Court for an in camera review to determine whether
the matters constitute "fact work product", "opinion work product" or merely "contention
discovery".
DONE AND ORDERED this /¶ay eifJuly, 2011 at West Palm Beach, Palm
l
Beach County, Florida.
L
DAVITS F. CROW
CIRCUIT COURT JUDGE
Copy furnished:
JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409
JOSEPH L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 Phillips Point West, West Palm
Beach, FL 33401
JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401
MARC NURIK, ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301
GARY M. FARMER, JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301
MARTIN WEINBERG, ESQUIRE, 20 Park Plaza, Suite 1000, Suffolk, MA 02116
EFTA00591507
DataSet-9
Unknown
1 pages
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No: 10-80447-cv-Marra/Johnson
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSMON OF:
NAME: DATE AND TIME: - LOCATION:
May 18, 2010
10:00 AM
upon an oral examination before Videograpber and a Notary Public or officer authorized by law
to take depositions in the State of Florida. The oral examination will continue from day to day until
completed. The depositions are being taken for purposes of discovery, for use at trial or are being
taken for such other purposes as are permitted under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed thisZ
day of April 2010 to Jack A. Goldberger, Ulit
Bruce E. Reinhart, Esq.,..1i
Robert D. Critton, Jr., Michael
LEOPOLD-KUVIN, P.A.
Spencer Kuvin, Esq.
Florida Bar No: 089737
EFTA00611589
DataSet-10
Unknown
1 pages
To: Jeevacation[leevacation6gmaitcomj
From: Lesley Groff
Sent Fri 12/17/2010 8:27:55 PM
Subject: Steve Osber
From: [mailto
Sent: Friday, December 17, 2010 3:24 PM
To: Lesley Groff
Subject: Re: Jeffrey Epstein
I am in a deposition in California. I will call u on a break to coordinate a meeting. Thanks.
Sent via BlackBerry by AT&T
From: "Lesley Groff"
Date: Fri, 17 Dec 2010 15:08:13 -0500
To: 'Ma
Subject: Jeffrey Epstein
Hello Mr. Osber. Jeffrey Epstein would like to speak with you and asked if we could coordinate
a time for the two of you to speak today sometime after 4:15. I had phoned your office and
understand you are out. Your assistant suggested I send you an email.
Thank you,
Lesley
Assistant to Jeffrey Epstein
EFTA_R1_00207835
EFTA01831080
DataSet-11
Unknown
1 pages
From: Jean Luc Brunel
Sent: Wednesday, September 19, 2012 7:15 PM
To: [email protected]
Subject: oct 4th
deposition =?xml version=.0" encoding=TF-8"?>
conyersation-idgkey>
230901
date-last-viewed
0
date-received
1348082117
flags
8623750145
gmail-label-ids
6
2
remote-id
246827
1
EFTA_R1_01721631
EFTA02560592
DataSet-9
Unknown
1 pages
From: "Martin G. Weinberg" •MINIM>
To: [email protected]>,
Subject: ATTORNEY-CLIENT PRIVILEGE
Date: Fri, 09 Jan 2015 16:45:01 +0000
Importance: Normal
Attachments: Witness_-_5th_-_harassment_to_question_witness_after_taking_the_5th.rtf
A case where a federal court imposed sanctions for continued questioning at a deposition after the witness asserted the
5th Amendment Researching Fla law if any on this issue. May be federal pleading opposing joinder filed today or no later
than next week. If it is strong enough may, in combination with other matters, including those you've identified, provide
some reasons why Cassell may be persuaded that a the lawsuit is not in anyone's interest which could open door to a
cease fire.
EFTA00867012
DataSet-10
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 10-80309
JANE DOE NO. 103
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
CROSS-NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that at the below listed time and place the Plaintiff, JANE DOE
NO. 103, by and through undersigned counsel, will take the depositions of:
NAME OF DEPONENT DATE AND TIME PLACE OF DEPOSITION
Monday Prose Court Reporting
March 1, 2010 250 S. Australian Ave.
10:00 a.m. Suite 1500
West Palm Beach, FL 33401
Wednesday Same as above.
March 24, 2010
10:00 a.m.
upon oral examination before PROSE COURT REPORTING, a Notary Public, or any other notary
public or officer authorized by law to take depositions in the State of Florida. The oral examination
will continue from day to day until completed. This deposition is being taken for the purpose of
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800. Miami, FL 33130. Muni *Ins MR HBO) Fax 305 AM nit, • Fort Lauderdale 954.463.4346 www.podhurstsorn
EFTA_R1_00012996
EFTA01734609
EFTA_R1_00012997
EFTA01734610
DataSet-10
Unknown
10 pages
AO 88A (Rev 112/I4) Subpccna to 'testify a: a IXposi6on in 2 Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District ofNew York
v. Civil Action No.
Ghislaine Maxwell
Defendant
SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
To:
(Name ofperson to whom this subpoena is directed)
I Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
deposition to be taken in this civil action. If you are an organization, you must designate one or more officers, directors,
or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or
those set forth in an attachment:
!Place: boies, Schiller & Flexner Date and Time:
575 Lexington Avenu 06/09/2016 9:00 am
Now York, NY 10022
The deposition will be recorded by this method: Stenographically and Videotaped
1 Production: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the
material: See Schedule A attached.
The following provisions of Fed. IL Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date: 05/17/2016
CLERK OF COURT
OR
_ .
Signature ofClerk or Deputy Clerk
The name, address, e-mail address, and telephone number of the attorney representing (name ofparty)
, who issues or requests this s
401 E. Las 0las Blvd., Suite 1200, FL Lauderdale. FL 33301; Tel:
o ice to t e person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things before
trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to
whom it is directed. Fed. R. Civ. P. 45(aX4).
EFTA_R1_00014480
EFTA01734932
AO 88A (Rev 02i:,) Subpoena to Testify e: o Deposition in a Civil Action (Pare 3)
Federal Rule of Civil Procedure 45 (c), (d), (c), and (0 (Effective 12/1/13)
(e) Plate of Compliance. (i) disclosing a trade secret a other confidential research, development.
or commercial information; or
(I) For a Trial, Hearing, or Deposition. A subpoena may command • 01) disclosing an wuttained expert's opinion or information that does
person to attend a teal, hearing, or deposition only as follows: not describe specific occurrences in dispute and results from the expert's
(A) within 100 miles of where the person resides, is employed, or study that was not requested by a party.
regularly transacts business in pa-son; or (C) Specifying Conditions as an Alternattve. In the circumstances
(8) within the state where the person resides, is employed, or regularly described in Rule 45(d)(3)(1)), the cowl may, instead of quashing or
transacts business in person, if the person modifying a subpoena, order appearance or production under specified
(i) is a party or a party's officer, or conditions if the serving party.
(Ii) is commanded to attend a trial and would not incur substantial (I) shows a substantial need for the testimony or material that cannot be
expense. otherwise met without undue hardship; and
(ii) assures that the subpoenaed person will be reasonably compensated.
(2) For Other Discovery. A subpoena may command:
(A) production of documents, electronically stored information, or (e) "Witt in Responding to a Subpoena.
tangible things at a place within 100 miles of where the person resides, is
employed. or regularly transacts business in person; and (I) Producing Documents or Electronically Stored Information. These
(8) inspection of premises at the premises to be inspected. procedures apply to producing documents or electronically strafed
information:
(d) Protecting • Person Subject to a Subpoena; Enforcement. (A) Documents A person responding to a subpoena to produce documents
must produce them as they arc kept in the ordinary course ofbusiness or
(1)AvoldIng Undue Burden or Expense; Sanctions. A party or attorney must organize and label them to correspond to the categories in the demand.
responsible for issuing and serving a subpoena must take reasonable steps (B) Formfor Producing Elecrronicalo, Stored Information NatSpecifled
to avoid imposing undue burden or expense on a person subject to the If a subpoena does not specify a form for producing electronically stored
subpoena. The court for the district where compliance is required must information, the person responding must produce it in • form or forms in
enforce this duty and impose an appropriate sanction—which may include which it s ordinarily maintained or in a reasonably usable form or NOW
lost earnings and reasonable attorney's foes--on a pony or attorney who (C) Electronically Stored Information Produced in Only One Form. The
fails to comply. person responding need not produce the same electronically stored
information is mom then one form.
(2) Command to Produce Materials or PermitInspection. (12) Inaccessible Electronically Stored Information The person
(A) Appearance Not Required. A person commanded to produce responding need not provide discovery of electronically stored information
documents, electronically stored information, or tangible things, or to from sources that the person identifies as not reasonably accessible because
permit the inspection ofpremises, need not appear in person at the plats of ofundue burden or cost. Cm motion to compel discovery or for a protective
production or inspection unless also commanded to appear for a deposition, order, the person responding must show that the information is not
heating, or trial. reasonably accessible because ofundue burden or cost. If that showing is
(B) Objections. A person commaoded to produce documents or tangible made, the court may nonetheless order discovery from such sources if the
things or to permit inspection may serve on the party or attorney designated requesting party shows good cause, considering the limitations of Rule
in the subpoena a written objection to inspecting. copying, testing, or 26(bX2)(C). The court may specify conditions for the discovery.
sampling any or all of the materials or to inspecting the protases—or to
producing electronically stored information in the form or fount requested. (2)C:dining Privilege or Protection.
The objection must be served before the earlier of the time specified for (A)Information Withheld A person withholding subpoenaed information
compliance or 14 days alto the subpoena is served. Iran objection is made. undo a claim that it is privileged or subject to protection as trial-preparation
the following rules apply: material must:
(i) At any time, on notice to the commanded person, the serving party (i) expressly make the claim; and
may move the court for the district where compliance is required for an (II) describe the nature of the withheld documents, communications, or
order compelling production or inspection tangible things in a manner tiµ without revealing information itself
(II) These acts may be required only as directed in the order, and the privileged or protected, will enable the panics to assess the claim.
order must protect a person who is neither a party nor a party's officer from (B) Information Produced. If information produced in response to a
significant expense resulting fionn compliance. subpoena is subject to a claim ofprivilege or ofprotection as
trial-preparation material, the person making the claim may notify any pasty
(3) Quashing or Modifying a Subpoena that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
(A) When Required On timely motion, the court for the district where information and any copies it has; must not use or disclose the information
compliance is required must quash or modify a. subpoena that: until the claim is resolved; must take reasonable steps to retrieve the
information if the party disclosed it before being notified; and may promptly
(I) ails to allow a reasonable time to comply. present the information coda seal to the coun for the district where
(Ii) requires a person to comply beyond the geographical limits compliance is required for a determination of the claim. The person who
specified in Rule 45(c). produced the information must preserve thc information until the claim is
(III) requires disclosure of privileged or other protected matter, ifno resolved
exception or waiver applies; or
(Iv) subjects a person to undue burden. (g) Contempt.
(B) {Phan Permuted To protect a person subject to or affected by a The court for the district where compliance is required—and also, after a
subpoena, the coon for the district where compliance is required may, on motion is transferred, the issuing omit—may hold in contempt a person
motion, quash or modify the subpoena if it requires: who, having been served, fails without adequate excuse to obey the
subpoena or an order related to it.
For access to subpoena materials. sec Fed. R Civ. P. 45(o) Committee Note (2013).
EFTA_R1_00014481
EFTA01734933
To: Luciano Fontanilla a/k/a Jo Jo Fontanilla
EXHIBIT A
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. "Agent" shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
2. "Correspondence" or "communication" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. "Document" shall mean all written and graphic matter, however produced or
reproduced, and each and every thing from which information can be processed, transcribed,
transmitted, restored, recorded, or memorialized in any way, by any means, regardless of
technology or form. It includes, without limitation, correspondence, memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
EFTA_R1_00014482
EFTA01734934
To: Luciano Fontanilla ailda Jo Jo Fontanilla
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, c-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telccopies, invoices, worksheets, printed matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
"writings" and "recordings" as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are not available. Any document with any marks
such as initials, comments or notations of any kind of not deemed to be identical with one
without such marks and is produced as a separate document. Where there is any question about
whether a tangible item otherwise described in these requests falls within the definition of
"document" such tangible item shall be produced.
4. "Employee" includes a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
5. "Including" means including without limitations.
6. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein.
7. "You" or "Your" hereinafter means Luciano Fontanilla and any employee, agent,
attorney, consultant, related entities or other representative of Luciano Fontanilla.
2
EFTA_R1_00014483
EFTA01734935
To: Luciano Fontanilla a/k/a Jo Jo Fontanilla
INSTRUCTIONS
1. Production of documents and items requested herein shall be made at the offices
of Boies Schiller & Flexner, LLP, 401 East Las Olas Blvd., Suite 1200, Ft. Lauderdale, FL,
33301, no later than five (5) days before the date noticed for your deposition, or, if an alternate
date is agreed upon, no later than five (5) days before the agreed-upon date.
2. Unless indicated otherwise, the Relevant Period for this Request is from 1996 to
the present. A Document should be considered to be within the relevant time frame if it refers or
relates to communications, meetings or other events or documents that occurred or were created
within that time frame, regardless of the date of creation of the responsive Document.
3. This Request calls for the production of all responsive Documents in your
possession, custody or control without regard to the physical location of such documents.
4. If any Document requested was in your possession or control, but is no longer in
its possession or control, state what disposition was made of said Document, the reason for such
disposition, and the date of such disposition.
5. For the purposes of reading, interpreting, or construing the scope of these
requests, the terms used shall be given their most expansive and inclusive interpretation. This
includes, without limitation the following:
a) Wherever appropriate herein, the singular form of a word shall be
interpreted as plural and vice versa.
b) "And" as well as "or" shall be construed either disjunctively or
conjunctively as necessary to bring within the scope hereof any
information (as defined herein) which might otherwise be construed to be
outside the scope of this discovery request.
c) "Any" shall be understood to include and encompass "all" and vice versa.
d) Wherever appropriate herein, the masculine form of a word shall be
interpreted as feminine and vice versa.
3
EFTA_R1_00014484
EFTA01734936
To: Luciano Fontanilla a/Ic/a Jo Jo Fontanilla
c) "Including" shall mean "including without limitation."
6. If you are unable to answer or respond fully to any document request, answer or
respond to the extent possible and specify the reasons for your inability to answer or respond in
full. If the recipient has no documents responsive to a particular Request, the recipient shall so
state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning, referring to, responding to, relating to, pertaining to, connected with,
comprising, memorializing, evidencing, commenting on, regarding, discussing, showing,
describing, reflecting, analyzing or constituting.
9. "Identify" means, with respect to any "person," or any reference to the "identity"
of any "person," to provide the name, home address, telephone number, business name, business
address, business telephone number and a description of each such person's connection with the
events in question.
10. "Identify" means, with respect to any "document," or any reference to stating the
"identification" of any "document," provide the title and date of each such document, the name
and address of the party or parties responsible for the preparation of each such document, the
name and address of the party who requested or required the preparation and on whose behalf it
was prepared, the name and address of the recipient or recipients to each such document and the
present location of any and all copies of each such document, and the names and addresses of all
persons who have custody or control of each such document or copies thereof.
4
EFTA_R1_00014485
EFTA01734937
To: Luciano Fontanilla a/k/a Jo Jo Fontanilla
11. In producing Documents, if the original of any Document cannot be located, a
copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same
manner as the original.
12. Any copy of a Document that is not identical shall be considered a separate
document.
13. If any requested Document cannot be produced in full, produce the Document to
the extent possible, specifying each reason for your inability to product the remainder of the
Document stating whatever information, knowledge or belief which you have concerning the
portion not produced.
14. If any Document requested was at any one time in existence but are no longer in
existence, then so state, specifying for each Document (a) the type of document; (b) the types of
information contained thereon; (c) the date upon which it ceased to exist; (d) the circumstances
under which it ceased to exist; (e) the identity of all person having knowledge of the
circumstances under which it ceased to exist; and (1) the identity of all persons having
knowledge or who had knowledge of the contents thereof and each individual's address.
15. All Documents shall be produced in the same order as they are kept or maintained
by you in the ordinary course of business.
16. You are requested to produce all drafts and notes, whether typed, handwritten or
otherwise, made or prepared in connection with the requested Documents, whether or not used.
17. Documents attached to each other shall not be separated.
18. Documents shall be produced in such fashion as to identify the department,
branch or office in whose possession they were located and, where applicable, the natural person
in whose possession they were found, and business address of each Document's custodian(s).
5
EFTA_R1_00014486
EFTA01734938
To: Luciano Fontanilla a/k/a .To Jo Fontanilla
19. If any Document responsive to the request is withheld, in all or part, based upon
any claim of privilege or protection, whether based on statute or otherwise, state separately for
each Document, in addition to any other information requested: (a) the specific request which
calls for the production; (b) the nature of the privilege claimed; (c) its date; (d) the name and
address of each author; (e) the name and address of each of the addresses and/or individual to
whom the Document was distributed, if any; (f) the title (or position) of its author; (g) type of
tangible object, e.g., letter, memorandum, telegram, chart, report, recording, disk, etc.; (h) its title
and subject matter (without revealing the information as to which the privilege is claimed); (i)
with sufficient specificity to permit the Court to make full determination as to whether the claim
of privilege is valid, each and every fact or basis on which you claim such privilege; and (j)
whether the document contained an attachment and to the extent you are claiming a privilege as
to the attachment, a separate log entry addressing that privilege claim.
20. If any Document requested herein is withheld, in all or part, based on a claim that
such Document constitutes attorney work product, provide all of the information described in
Instruction No. 19 and also identify the litigation in connection with which the Document and the
information it contains was obtained and/or prepared.
21. Plaintiff does not seek and does not require the production of multiple copies of
identical Documents.
22. This Request is deemed to be continuing. If, after producing these Documents,
you obtain or become aware of any further information, Documents, things, or information
responsive to this Request, you are required to so state by supplementing your responses and
producing such additional Documents to Plaintiff.
6
EFTA_R1_00014487
EFTA01734939
To: Luciano Fontanilla a/k/a Jo Jo Fontanilla
DOCUMENTS TO BE PRODUCED PURSUANT TO THIS SUBPOENA
1. All documents related to Jeffrey Epstein.
2. All documents relating to Ghislaine Maxwell.
3. All documents relating to
4. All documents related to
5. All documents related to
6. All documents related to anyone giving massage to Jeffrey Epstein and Ghislainc
Maxwell.
7. All documents related to any massages that took place on Jeffrey Epstein's
residences.
7
EFTA_R1_00014488
EFTA01734940
TD BANK
AMERICAS MOST CONVENIENT SANK
13344
I.I367/210
EXECPROTECT INC 164
DBA ALPHA GROUP
SUBPOENA ACCOUNT
100 BROADHOLLOW RD STE 200 5/17/2016
FARMINGDALE, NY 11735
PAY TO THE
ORDER OF Luciano Fontanilla $ ' 1169.16
riti. • • *** *ire ...... tette* le* • • • I
Sixty-Nine and 16/100"*"" DOLLARS
Luciano Fontanilla
MEMO
civil action# s
EFTA_R1_00014489
EFTA01734941
DataSet-9
Unknown
6 pages
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
FORT LAUDERDALE DIVISION
www.flsb.uscourts.gov
IN RE: CASE NO.: 09-34791-RBR
ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11
Debtor.
RE-NOTICE OF TAKING VIDEO DEPOSITION DUCES TECUM
TO: All counsel on the attached Counsel List
PLEASE TAKE NOTICE that the undersigned attorneys will take video deposition of:
NAME AND ADDRESS DATE AND TIME LOCATION
Jeffrey Epstein August 17, 2018 Searcy Denney Scarola
Barnhart & Shipley, P.A.
1:00 p.m. 2139 Palm Beach Lakes
Boulevard
West Palm Beach, FL 33409
VIDEOGRAPHER: Above & Beyond Reprographics, Inc.
upon oral examination before Palm Beach Reporting, Inc., a Notary Public; or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the
applicable Statutes or Rules.
*DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF
THE DEPOSITION THE FOLLOWING:
EFTA00801668
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
Re-Notice of Taking Video Deposition
Page 2
DUCES TECUM*
All communications and all records relating to all communications concerning or
containing information derived from documents or data over which a claim of
privilege was asserted by or on behalf of Rothstein Rosenfeldt Adler, P.A., Farmer,
Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., or Bradley J. Edwards.
*"Documents" shall include, but not be limited to all non-identical copies of writings,
drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data
compilations from which information can be obtained, translated, if necessary, by the party to
whom the request is directed through detection devices into reasonably usable form. "Documents"
also include all electronic data as well as application metadata and system metadata. All
inventories and rosters of your information technology (IT) systems—e.g., hardware, software and
data, including but not limited to network drawings, lists of computing devices (servers, PCs,
laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
and security tools and protocols.
EFTA00801669
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
Re-Notice of Taking Video Deposition
Page 3
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
to all Counsel on the attached list, this 2.-6 day of (J 2018.
VITALE
Florida Bar No.:
Primary E-Mail:
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone:
Fax:
Attorneys for Bradley J. Edwards
cc: Palm Beach Reporting, Inc. (court reporter)
Above & Beyond Reprographics, Inc. (videographer)
E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED
EFTA00801670
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
Re-Notice of Taking Video Deposition
Page 4
COUNSEL LIST
Joseph L. Ackerman, Jr., Esq.
Fowler White Burnett, P.A.
901 Phillips Point West
777 South Flagler Drive
West Palm Beach, Florida 33401-6170
Phone:
Fax:
Attorneys for Jeffrey Epstein
Scott J. Link, Esq.
Link & Rockenbach, P.A.
1555 Palm Beach Lakes Boulevard
Suite 301
West Palm Beach FL 33401
Phone:
Fax:
Attorneys for Jeffrey Epstein
Jack A. Goldber er, uire
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue S, Suite 1400
West Palm Beach FL 33401
Phone:
Fax:
Attorneys for Jeffrey Epstein
Phil Burlington, Esq.
Nichole JiS r.tsire
Burlington & Rockenbach, P.A.
444 W Railroad Avenue, Suite 350
West Palm Beach, FL 33401
Phone:
Attorneys for Bradley J. Edwards
EFTA00801671
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
Re-Notice of Taking Video Deposition
Page 5
EDWARDS POTTI/siGER LLC
Bradley J. Edwards FLBN 54207
Brittany N. Henderson FLBN
Edwards Pottinger LLC
425 N Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone l
Fax:
Jay Howell
Jay Howell & Associates
Florida Bar No.:
Attorney E-Mail(s):
644 Cesery Blvd. #250
Jacksonville, FL 32211
Paul G. Cassell
S.J. Quinney College of Law at the
University of Utah
332 S. University St.
Salt Lake City, UT 84112
(above for addressir se.s onl
Attorney E-Mail:
Attorneys for and Jane Doe
Joseph Iamio, Jr., Esquire
Carton Fields
CityPlace Tower
525 Okeechobee Boulevard, Suite 1200
West Palm Beach, FL 33401
Tele hone:
Fax:
Attorneys for Fowler White Burnett, P.A.
Isaac M. Marcushamer
Berger Singerman LLPO
1450 Brickell Avenue, Suite 1900
Miami, FL 33131
Counsel for Litigating Trustee
EFTA00801672
In Re: Rothstein Rosenfeldt Adler, P.A.
Case No. 09-34791-RBR
Re-Notice of Taking Video Deposition
Page 6
"If you are a person with a disability who needs any accommodation in
order to participate in this proceeding, you are entitled, at no cost to you,
to the provision of certain assistance. Please contact Americans with
Disabilities Act Coordinator at least 7 days before your scheduled court
appearance, or immediately upon receiving this notification if the time
before the scheduled appearance is less than 7 days; if you are hearing or
voice impaired, call 711."
"Si usted es una persona minusvilida que necesita algtin acomodamiento
para poder participar en este procedimiento, usted tiene derecho, sin
tener gastos propios, a que se le provea cierta ayuda. Tenga la
amabilidad de ponerse en contacto con Americans with Disabilities Act
Coordinator por lo menos 7 dias antes de la cita fijada para su
comparecencia en los tribunales, o inmediatamente despues de recibir
esta notification si el tiempo antes de la comparecencia que se ha
programado es menos de 7 dias; si usted tiene discapacitacion del oido o
de la voz, Ilame al 711."
"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe
nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen
pwovizyon pou jwen kik ed. Tanpri kontakte Americans with Disabilities
Act Coordinator nan 7 jou anvan dat ou gen randevou pou paret nan
tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon an si le
ou gen pou w park nan tribinal la mwens ke 7 jou; si ou gen pwoblem
pou w tande oubyen pale, rele 711."
EFTA00801673