Search: flight log

EFTA02109260.pdf

DataSet-10 Unknown 1 pages

To: greg©crowhurst.ws Cc: Lar Visosk From: Sent: Tue 4/8/2014 2:36:23 PM 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! 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 A14, 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_00728380 EFTA02109260

EFTA02108891.pdf

DataSet-10 Unknown 2 pages

To: Lesley Grof Cc: Larry Visoski From: Greg Wyler Sent: Tue 4/8/2014 7:16:55 PM Subject: RE: Jeffrey Epstein My cell is: See you soon. Original Message From: Lesley Groff [mailto:[email protected]] Sent: Tuesday, April 08, 2014 7:36 AM To: [email protected] 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: 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 viler • > 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 ?:08 AM, Lesley Groff a 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 EFTA_R1_00727455 EFTA02108891 EFTA_R1_00727456 EFTA02108892

EFTA00159712.pdf

DataSet-9 Unknown 8 pages

-1 of 8- FD.302(Ftev.5440 FEDERAL BUREAU OF INVESTIGATION Date of entry 02/09/2021 LARRY VISOSKI (VISOSKI), was interviewed pursuant to a proffer agreement via video conference with hos attorneys Glen McGorty, Daniel Zelenko and Danielle Giffuni present. Also present via video was Assistant United States Attorneys , Detective and Special Agent . After being advised of the identities of the above listed individuals and the nature of the interview, there was a discussion about the proffer agreement. VISOSKI states that he understands the proffer agreement, signs the document and shows it to the camera. VISOSKI then provides the following information: VISOSKI went to high school in . He then went to community college in Broward County for a year and a half. After that he went to aircraft mechanic trade school in Miami. He learned how to fly while being a mechanic. VISOSKI worked for JEFFREY EPSTEIN from July of 1991 until 2O19. He currently maintains his planes and helicopter that is for sale under EPSTEIN's estates. VISOSKI and DAVE RODGERS started working for EPSTEIN at the same time. VISOSKI and RODGERS had known each other from a previous job they had together based in Columbus Ohio. VISOSKI was the co-captain. One day EPSTEIN approaches VISOSKI and RODGERS in a corvette. VISOSKI talks with EPSTEIN about cars. EPSTEIN tells VISOSKI that he is now that car guy. VISOSKI then starts installing stereos in EPSTEIN's cars. Then he does home theater work on his island and the ranch. At this time, he is also flying the plane. VISOSKI started with 2 weeks of vacation, then had 4 weeks. There were other pilots that VISOSKI and RODGERS would contact when they needed time off. RODGERS had hired VISOSKI originally because he liked his mechanic skills. Someone at VISOSKI's previous job told VISOSKI that a friend of LEX New York, New York, United States (, Other (Video Investigation on 10/07/2020 at Conference)) FileN 50D-NY-3027571 Dmednifts 01/04/2021 II This document contains neither recommendations nor conclusions or the FBI. It is the property or the FBI and u loaned to your agency; it and its contents are not to be distributed OULU& your agency. 3527-005 Page 1 of8 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009905 EFTA00159712 ED.302a(Rev.54.10) 50D-NY-3027571 Contuntalion of ED.302 of (U) Interview/Proffer of LARRY VISOSKI .O, 10/07/2020 pas, 2 of 8 WEXNER's was buying a plane and would need a pilot. In 2001 they hired another pilot because of the boeing airplane upgrade. EPSTEIN or a secretary from New York would call RODGERS or VISOSKI and tell them what time EPSTEIN wants to leave. VISOSKI is asked about the documents that he maintains as a pilot: FLIGHT LOG: VISOSKI describes the flight log to be anytime the plane flew, it would get documented in this log. The cycles of the engine and the start and stop time would be documented on a spreadsheet. This does not contain information on passengers. PASSENGER MANIFEST: VISOSKI states this would be filled out after every flight by whoever was the captain that day. The co-pilot would assist in the rear of the plane. Sometimes the manifest was documented after the plane took off. If VISOSKI knew the names of the passengers VISOSKI would write them down. It was usually the same people that the pilots knew. Sometimes EPSTEIN would introduce new people. The pilots were more concerned about the head count and the weight of the persons. This would be a word document containing the date, takeoff and landing time. There would be 1 page for each flight. RODGERS was responsible for turning these documents into the office. VISOSKI never retained documents. These documents would go to New York. VISOSKI kept his own personal flight log which had his hours and destinations. The papers and binders of records were kept in the Palm Beach office and then were eventually transferred to the New York office. They were given to IIII, about 6-9 months of binders at a time to transfer to New York. They needed to keep track of how many days EPSTEIN was in a particular location. In the mid-2000's all the records were turned over to EPSTEIN's attorney JACK GOLDBERGER by RODGERS. VISOSKI only knew of the originals; he didn't know of copies. In 2008 there were about 5 years of built up records in Palm Beach that were getting faxed. Around 2008/2009 they stopped putting passenger names on the logs. 3527-005 Page2 oft; SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009906 EFTA00159713 FD-302a (Rev. 54-ID) 500-NY-3027571 CominualianoM402of (U) Interview/Proffer of LARRY VISOSKI O, 10/07/2020 " my 3 of B Around 2010/2011 EPSTEIN tells VISOSKI and RODGERS to stop putting passenger names and only put EPSTEIN on passenger manifest and sheets. [Agent note: At this point in the interview, VISOSKI pulled up a document on computer.] VISOSKI states that he is looking at RODGERS's pilot logbook. RODGERS had a personal logbook just for his flights. This includes passenger information but it is not a passenger manifest. Whoever flies the plane fills out the passenger manifest. One for each leg of the flight. VISOSKI did not keep passenger information on his personal flight log. VISOSKI states that the passenger manifests when flying the G2 plane were given to JACK GOLDBERGER prior to 2009. VISOSKI has the passenger manifest from 2009-present. [Agent note: These were already provided to VISOSKI's lawyer which has been turned over.) The flight logs went with the plane. VISOSKI is asked about RODGERS' personal pilot logbook. VISOSKI states he recognizes RODGERS handwriting. Maybe the first time that VISOSKI had seen it was in 2008 when it hit the internet. VISOSKI had seen RODGERS' handwriting on passenger manifests. VISOSKI does understand what each column stands for in this logbook. Column #1: Date (of each flight) Column #2: Model of aircraft Column #3: Registration I (the "N" number) Column #4: Airport departure Column #5: Airport landed Column #6: Duty time Column #7: Total flying time Column #8: Passenger names VISOSKI states that the total number of aircrafts he has flown for EPSTEIN is 5. VISOSKI is asked to turn to page 25 of the PDF file. On January 2, 1994 halfway down the page, leaving from Palm Beach to Teterboro. It states "JE + GM" on flight. VISOSKI states this is referring to EPSTEIN and MAXWELL. VISOSKI states RUSS and KIPAS flew who are friends with RODGERS. VISOSKI was not on this flight. 3527-005 Page 3 of 8 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009907 EFTA00159714 ED.302a(Rev.5440 50D—NY-3027571 continunnonotED.3o2ot (U) Interview/Proffer of LARRY VISOSKI .O, 10/07/2020 . past 4 of 8 Palm Beach to EPSTEIN was his home. EPSTEIN's office was 457 Madison Avenue in Manhattan. The Teterboro flights were for EPSTEIN to go to New York. MAXWELL to EPSTEIN was a shopper. She would furnish the homes the whole time. She decorated the plane. VISOSKI was not sure of their personal relationship. Possibly girlfriend and boyfriend but it was not super obvious. In the 90's EPSTEIN or MAXWELL would call to set up flights. Usually a secretary would call. VISOSKI would usually get notice the day before about travel. VISOSKI had a beeper back then. He would receive a beep and then he would call into the office. MAXWELL would do the same as the secretaries. It was common to talk to MAXWELL. On January 8, 1994, the flight was from PBI to OGA to SAV to FBI. On this flight was "JE, SE". VISOSKI could not recall who SB was. On January 15, 1994, the flight was from PBI to SEE to FPR to PBI. On this flight was "JE, SS, and CLAUDIA". VISOSKI did not remember CLAUDIA and could not recall her last name. On January 18, 1994, the flight was from PBI to TEB. On this flight was "JE, GM, and 2 females". VISOSKI did not recall who the two females were. Most of the time it was the same crowd who flew with EPSTEIN. With EPSTEIN having a private jet, there were "tagalongs". VISOSKI stated he was making assumptions they were tagalongs to why he did not know the names. When they traveled internationally, he would have to know the passengers names. When VISOSKI was asked if there was a time where he did not know a passenger's name then later learned it, he replied yes. VISOSKI learned passengers' names after he was introduced to them. They tried to keep the most accurate record of people. VISOSKI was directed to page 29. In July of 1994, JIM WARDEN and AL GATO appeared on the left side of the page. GATO was one of THE LIMITED pilots. On August 7, 1994, the flight was on the G1159B - this was one of the first trips in this plane. On August 16, 1994, was the flight from Midway to Aspen. On this flight 3527-005 Page 4 oft; SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009908 EFTA00159715 ED.302a(Rev.5440 SOD—NY-3027571 conimunnonotED.3o2of (U) Interview/Proffer of LARRY VISOSKI On 10/07/2020 p,st 5 of 8 was "JE, , and FRANCIS JARDINE". VISOSKI remembered but was drawing a blank on her connection to EPSTEIN. On August 18, 1994, was the flight from Aspen to Traverse City, Michigan. They went to Michigan more than once. This was where INTERLOCHEN was located. EPSTEIN was big on the arts and had a cabin there. On August 20, 1994, was the flight from Michigan to Teterboro. On this flight was "JE, GM, and VISOSKI recalled name but could not recall if she was a "massage person". When asked if on round trip flights if one leg passengers would be different from the return flights, VISOSKI stated yes it happened but it was not common. If someone wanted to stay in a certain location he/she would have to take a commercial return flight. VISOSKI was directed to page 34. On March 16, 1995, was the flight from Teterboro to Palm Beach. On this flight was "JE, RUPERT, DAVID ROTH, and 4 passengers". RUPERT was a British butler that was around for a year. Both RUPERT and ROTH's name were familiar to VISOSKI but he could not remember much about them. VISOSKI did not know who the names of the 4 passengers. On June 16, 1995, was the flight from Teterboro to Columbus. on this flight was "JE, ". VISOSKI recalled being around EPSTEIN, but without the last name listed on this flight VISOSKI could not be sure it was her on the flight. traveled with EPSTEIN and spent time on his plane. was a "shopper". She was a regular person who was around during that time. VISOSKI was directed to pay 40. On March 18, 1996, the flight was from Palm Beach to Columbus. On the flight was "JE, GM, III , and 1 female". VISOSKI recalled they had a chef named ANDY, but did not remember his last name. VISOSKI was unsure who "II" referenced. traveled on the plane more than one time. VISOSKI did not know relation to EPSTEIN. She was a frequent traveler in the "early days". On May 2, 1996, the flight was from Teterboro to EIDW which VISOSKI thought was London or Ireland. VISOSKI recalled LFPB was Paris, where EPSTEIN had an apartment. They went several times to Paris. They went to London in the early days; MAXWELL was from London. From the 1990s 3527-005 Pagesoft; SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009909 EFTA00159716 ED.302a(Rev.54.10) 50D-NY-3027571 comintnnonam.3020t DN Interview/Proffer of LARRY VISOSKI On 10/07/2020 pas, 6 of 8 on they would go to London occasionally. VISOSKI advised that nothing jumped out at him regarding the names ' and " D. On May 22, 1996, the flight was from Teterboro to Santa Fe. On this flight was "JE, GM" and JIM WARDEN was flying the plane. VISOSKI was not on this flight. EPSTEIN had a ranch in New Mexico. VISOSKI was directed to page 44, On October 24, 1996, the flight was from Teterboro to Santa Fe. On this flight was "JE, GM, and LARRY". VISOSKI thought this may have been LARRY SUMMERS. On November 11, 1996, the flight was from Palm Beach to Teterboro. On this flight was "JE, and friend, JEFF SCHANTZ and family, EVA, , and RUSS KIPPS". SCHANTZ was EPSTEIN's attorney. EVA's last name was ANDERSSON, who was a Miss Switzerland and one of EPTEIN's original girlfriends. . The only that VISOSKI could recall was KIPPS was the other pilot on this flight - VISOSKI was not on this flight. VISOSKI was asked if he recalled flying on EPSTEIN's plane and he stated he did not know but it was possible. VISOSKI remembered being around EPSTEIN. VISOSKI recalled traveled on the plane. VISOSKI remembered seeing on the plane; he recalled sitting in the cockpit and seeing her on the plane. This would have been in the 1990s. VISOSKI advised that sometimes people come onto the plane and sit for a while then leave before take off. VISOSKI did not recall was around first. was EPSTEIN or MAXWELL talked with VISOSKI about saying that she was . This was prior to . VISOSKI saw on the ramp in Palm Beach; she was standing on the entranceway to the cockpit. VISOSKI definitely recalled being on the plane at least one time. 3527-005 Page6of8 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009910 EFTA00159717 FU.3023 (Rev. 54.10) 50D-NY-3027571 Contumanom of ED.302 of (U) Interview/Proffer of LARRY VISOSKI On 10/07/2020 1,n , 7 of 8 On May 9, 1997, the flight was from Teterboro to Santa Fe. On this flight was "JE, GM, and ". VISOSKI did not know whether this . Without another pilot listed, there was a good chance VISOSKI was on this flight. On August 17, 1997, the flight was from Palm Beach to Martha's Vineyard. On this flight was "JE, VISOSKI could not remember anything about IIII On October 17, 1997, the flight was from Teterboro to Palm Beach. On this flight was "JE, GM, IIII, 1 female, The only IIII that VISOSKI knew was IIII VISOSKI assumed that . There was also a French chef on this flight. On May 3, 1998, the flight was from Palm Beach to Teterboro. On this flight was "JE, GM, GLEN, EVA, ". VISOSKI did not know was on this flight. On January 26, 2001, the flight was from Teterboro to Palm Beach. On this flight was "JE, GM, III IIII II was IIII . II flew on the plane sometimes. VISOSKI was not sure of IIII role with EPSTEIN. On September 3, 2001 the flight was from St. Thomas to HPN. VISOSKI states that St Thomas was where EPSTEIN's island was located and HPN is White Plains New York. On this flight was "II + is unknown to VISOSKI and On December 15, 2002 the flight from St. Thomas to Palm Beach. On this flight was "JE, GM, ■, ■". VISOSKI states ■ is , ■ is unknown. is another female who traveled on the plane. was sister. VISOSKI does not know who is. On September 22, 2003 the flight was from Palm Beach to St Thomas. On the flight was "JE and II" (not sure who this is). _- • • (not sure who this is). • (not sure who 3527-005 Page 7 of S SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009911 EFTA00159718 ED.302a(Rev.5440 50D-NY-3027571 Contsnuanon of ED.302 of (U) Interview/Proffer of LARRY VISOSKI On 10/07/2020 pas, 8 of 8 this is). On January 15, 2004 the flight was from JFK to Palm Beach. JE and II . • (not sure who this is). II (possibly . LV (VISOSKI). LM (LARRY MORRISON). VISOSKI is asked about other times being interviewed. He states that around 2004 VISOSKI was interviewed by FBI subpoena. Around 2006 VISOSKI was deposed by BRAD EDWARDS for a civil lawsuit. VISOSKI has never spoken to the media. 3527-005 Page 8 of8 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000099 I 2 EFTA00159719

EFTA01267546.pdf

DataSet-10 Unknown 63 pages

EFTA01267546 - • I • N N Lc' 0 z 0 LAWRENCE VISOSKI Given in recognition of your successful completion of the Gulfstream IV Recurrent - 4 Day Training Program w this Twentieth day of December 0 Two Thousand Eighteen LL 0 Center Leader Aviation and Training Services CAE Gutlfstroam IV / 8556490 Notice of Resignation Please be advised that effective upon the closing of the purchase and sale of all tne outstanding Membership Interests of JEGE, LLC, a U.S. Virgin Islands limited liability company (the "Company"), pursuant to the provisions of that certain Membership Interest Purchase Agreement, dated May 2, 2019, by and between Jeffrey Epstein, as the Seller, and Aviation Development Group, as the Purchaser, the undersigned, Lawrence P. Visoski, Jr., hereby resigns as the Manager of the Company. Dated: June 12, 2019 Lawrence P. Visoski, Jr. SDNY_GM_DOO11402 CONFIDENTIAL EFTA_00 I 22056 EFTA01267547 117 7,0 427- ,lorciE //A00 5-- /.7g / t(f 00 4 115e ,2/?0,0 7 /g„13 — /91,4 / °/ 0,:=J) /9,5 - //,79720o? .204'7— doc,„z i~ro1ao,o es3 — a) 37 // (3i' Al?c, /7//ao/A aa7p '7/7/4 o i3 AR3 9 — RR P Algoo-s,ce-D, et,P/20/3 iv Pe.Ve x 7,9-Aik Id /3--fix,s — 776 SDNY_GM_00011903 CONFIDENTIAL EFTA_DO 122057 EFTA01267548 C- — /4-1Z, c ni-722_,JE g76 c-rr C- 3/a 6/goi0 - 3 /O2,f/16it CONFIDENTIAL -- --- EFTA_DO122058 EFTA01267549 Shmitka Air, Inc. Flight Logs N722JE Serial 5 760750 576C++ Larry Visoski cell 55r - PAy pr 5— Date: 3 - —1 I To: tom: .Flay - 58y Trip # 3 Pilot: Co-Pilot: ' Airframe: 4 oZ Landings: ./ S3 + s Total 1 9, Total / 5-(=> Total _ Engine #1 -7(-1 k-:a Starts: 14/-i N1 cycles . N2 cycles / ' + cis + 3 (Cycles are recorded from aircraft IlDs panel) Total: -.7 9 ,6 Engine #2 4, pl.—Starts- N2 cycler` _; _N2 cycles — + 3 Total: _ ;°_ Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: 56- FAy H971,7 FA y- .5/3,, it53 1,8 (1(7 t.3 SDNY_GM_00011405 CONFIDENTIAL EFTA_OOI 22059 EFTA01267550 Shmitka Air, Inc. Flight Logs N722JE Serial tl 760750 576C++ Larry Visoski cell - Paz - ' Phcfro EXiifill4 II-36 Date: / To: p- rom: filiaP( — 161EF ./. Trip # 34( Pilot: /-44,-2e &od a / .7 , Co-Pilot: Nicolfrti4s..1weeQck" Airframe: 16 5, Landings: .5t 1 _3 Total Total / 5_3 Total . _ Engine #1 -G9. / Starts: J41 N1 cycles N2 cycles / / (Cycles are recorded from aircraft IlDs panel) Total: /(79 Engine #2 b9,/ Starts•j41.4. N2 cycler, _N2 cycles + 3 Total: _ cbg. Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: i govt> eickJivi0 1, 1 4-,.a(.> e?cmA - pis ) • Fr t so M,„, p6,7- - SST SDNY_GM_00011406 FietlkiTiAL EFTA_OOI 22060 EFTA01267551 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell - ' 51--/-.._ -7—JR& 0 ogi.luel. Date: ',3—,7c=7 —// To: S-H-ASJ-≤+71-- tom: 77) - M P PV Pg6tEn,c'AZ Trip #3,'R Pilot: 1-Aa-ay Viiivg Co-Pilot: 10... IVALJA ei_v;._/. Airframe: 6,(,, i Landings:_2 .z6 • _ 471 Total 64, Total a Total _ Engine #1 -6,4, ) Starts: i-ga N1 cycles N2 cycles / 3. 0 -4 (Cycles are recorded from aircraft IlDs panel) Total: h<9., / v6. Engine #2"-Z, / Starts. J'VQN2 cycler, _ N2 cycles Total: 0 (1_ I qe, Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: - sit aka . TJBQ 4-45) 771.6Q- "rIPPV SDNY_GM_00011407 7 -0T/42-- Cif WPFHTIAL EFTA_OOI 22061 EFTA01267552 (. Shmitka Air, Inc. Flight Logs N722jE C Serial 5 760750 576C++ Larry Visoski cell Date: c>) -) q -- 1/ To: .'"7-T- X sJ - s T7--- zsrgsm—.-C7r- 4 SV - TS" X - 2- Si-Si it- Trip # 3 Pilot: I Co-Pilot: • . Airframe: 6q, C, Landings: ./ 3 k + t , 3 + _ g Total --/a2 /I Total / 474 6 Total Engine #1 -6-41 , 6> Starts: 13 N1 cycles N2 cycles / • + /-5 + (Cycles are recorded from aircraft IlDs panel) Total: qc2 Engine #2 log, Starts- ) N2 cycle - _N2 cycles , Total: Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011408 CONFIDENTIAL EFTA_OOI 22062 EFTA01267553 Shmitka Air, Inc. Flight Logs N722JE Serial a 760750576C++ Larry Visoski cell Date: bfriacit To: - rOM: '/ Trip # Si Pilot: 4 D Tecnteu- Co-Pilot: "L_Vt osie_i Airframe: 63. 6 Landings:13 q + -, . 0 + 4 Total CA. (4, Total I 3? Total _ Engine #1 7 40 3M Starts: .12.1 NI cycles N2 cycles / + GI + (Cycles are recorded from aircraft IlDs panel) Total: ge 41.(4. .1-3t Engine #2 Ce3. e Starts. 134- N2 cycler -_ _N2 cycles + I,.•O Total: _ 2)/ Fuel Burned: Fuel Purchased: 5-D‘pt-t— Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011409 CONFIDENTIAL EFTA_00 122063 EFTA01267554 Shmitka Air, Inc. Flight Logs N722JE Serial 5 760750 576C++ Larry Visoski IMM cell SW - 4 Sd - 7i.),4 -/V A Date: / - 7 - 1/ To: 7i) /04,- Aree.e.sce-1.4)rom: L.Sj -,91i•Fr• Trip # Pilot: i 1,1441 11 Co-Pilot: /10/47-1461-A-k Airframe: 6,c9-,3 Landings: za5 + •1.3 Total 6,3, 7 Total /gfensz) Total Engine #1 - Starts: . I 5 N1 cycles /IL, 9 N2 cycles .42/. ?/ + 3 + (Cycles are recorded from aircraft IlDs panel) Total: 6.3:C, Engine #2 4 .;2, 3 Starts- cycler, 07,0 N2 cycles , Aka/ + /3 Total: _ 1 Fuel Burned: Fuel Purchased: `4/-6 Take off time: /: Landing time: /©W/ool Flight time: / Passenger: J6 Passenger: , Q Passenger: ‘ovezAze 0 e.liatpso,i Passenger: Passenger: ,64,AJ (2c ),L Passenger: Passenger: Passenger: SDNY_GM_00011410 CONFIDENTIAL EFTA_00122064 EFTA01267555 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell _ . Date: raia,yro z,2-11cade'rom: A-X4vecut 444-4.) Trip # O , 2 Pilot: ,A,Vac, SA v*".4,O,.,g. S-11- Airframe: Landings: ./. L.) + Total 4,,R. 3 Total Total _ Engine #1 421_ Starts:Zap N1 cycles N2 cycles / ca-R + 3 (Cycles are recorded from aircraft IlDs panel) Total: Engine #2 Starts. MO N2 cycler, - _N2 cycles Total: Fuel Burned: Fuel Purchased: 7 :544%%1 c,5 1 5715—P, Take off Me: 941901 Landing time: Flight time: ‘-,1(:)5' (rif Passenger: u S7 1-67) Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011411 CONFIDENTIAL EFTA_00I 22065 EFTA01267556 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell "-I- Date: /O/ -do -20 /0 To: 444 - 4•SJ- Stf" 4.Fi-O.r-n f-4 - .-i-f--isj-S.1+ Trip # JV Pilot: pe. V.so 3 K, Co-Pilot: /V.liii-Jia-urc12 Airframe: 5-6-/ Landings: /4,- + 41, b + e Total 6 0 . / Total /01, 6 Total 9 Engine #1 s6 • / Starts: // 0/ N1cycles 103. 8 N2 cycles / 0 Co , 7 + 4.D + / (Cycles are recorded from aircraft IlDs panel) Total: 620 /02-0 Engine #2 5-6 . / Starts: /42- N2 cycles/05-.3 N2 cycles / 0 P.44 + Total: 0 •I 4,2-O Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: CONFIDENTIAL SDNY-G"3"412 EFTA_00122066 EFTA01267557 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C-H- Larry Visoski cell Date: q -ao —0 To: Sti:—/-SJ-I From: ? 1- 71(1.0-7;1?,i( --- ,- Trip # 2227 Pilot: ii_566/ Co-Pilot: A/RA:og Airframe: 5-V• Landings: ii)6, + /(<72, + 6,, Total 5 ‘.,- / Total // Total ,5—; Engine #1 5---(7/- Starts: /61 0 N1cycles N2 cycles + (<9 - + e:' (Cycles are recorded from aircraft IlDs panel) Total: -5 6, 1 /c 9/ , Engine #2 5V. P starts:41 N2 cycles g3Jk N2 cycles ,et) el + + Total: /69. Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011413 CONFIDENTIAL EFTA_OOI 22067 EFTA01267558 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell Date: 5' - / q- /0 To: :13 4- . From: S7/71 - LJY Trip # oZk, Pilot: /Lad' Co-Pilot: Airframe: c (7 Landings: /S — + , 5.-- + C) Total 5 - (/ , ? Total /o7 Total Engine #1 el Starts: /CS--N1cycles N2 cycles `5"-- (Cycles are recorded from aircraft IlDs panel) Total: 07. / C 4. Engine #2 6V, 7Starts: /0-.5N2 cycles N2 cycles . Total: .5--V 9 /0 Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011414 CONFIDENTIAL EFTA_00122068 EFTA01267559 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ Larry Visoski cell Date: —(0 / To: S-H - A-Sci From: S f t Trip # Vs-es72 Co-Pilot: Nlel-44-4' Airframe: 53,7 Landings: -27 :7 Total 5- `71, 47/ Total /DC Total Engine #1 Starts: 9'4? N1 cycles 1, S N2 cycles gC. / :7 + („, (Cycles are recorded from aircraft IlDs panel) Total: 5-4-/ ,`/- /05" Engine #2 53,7 Starts: 9 (7 N2 cycles 2T; N2 cycles cg, 7 ‘c, Total: 5 -'74'7 / 03 Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: CONFIDENTIAL sc' m-DD°11415 EFTA_00122069 EFTA01267560 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ Larry Visoski cell Date: wiaiaotc, To: --rcs-r — LEA From: -ri-s-r Trip # Pilot: L Co-Pilot: Airframe: sR3 Landings: no o.. Total Total Total Engine #1 5- 2.9 Starts: cts- N1 cycles N2 cycles + O, (Cycles are recorded from aircraft IlDs panel) Total: 5-3 11 Engine #2 SZ °I Starts: ¶4 N2 cycles N2 cycles + 0 Total: nn V( Fuel Burned: Gto Fuel Purchased: -70 Take off time: o-qs Landing time: it, co Flight time: 0.4.41 Passenger: -a +- 6 Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011416 CONFIDENTIAL EFTA 00122070 EFTA01267561 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750576C++ Larry Visoski cell Date: l i en fib To: -nr - From: mrs—r— Trip # a:3 Pilot: )›. Co-Pilot: L Viso ke, Airframe: sa ---? Landings: 4.1( + O,2 + a Total 5a,9 Total 70 Total Engine #1 5"2 Starts: ci3 N1 cycles N2 cycles + G. a + 2 (Cycles are recorded from aircraft IlDs panel) Total: 52.9 Engine #2 s-an Starts: qs N2 cycles N2 cycles + O.a. Total: S 2 .9• (14 Fuel Burned: 2» - Fuel Purchased: Take off time: to Lis Landing time: I I or Flight time: or tz Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SONY_GM_00011417 CONFIDENTIAL EFTA_00122071 EFTA01267562 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell Date: via. / io To: --ns-r- From: -11'S-c- Trip # as Pilot: L Vi-strnd% Co-Pilot: 'b. ZTheti_ Airframe: 5-R • 3 Landings: 44 + 0.4 + Al Total ca • 7 Total co•TI Total Engine #1 5-23 Starts: 9a N1 cycles N2 cycles o + I (Cycles are recorded from aircraft IlDs panel) Total: 1 S 2 •- q3 Engine #2 sg .3 Starts: Si N2 cycles N2 cycles + O .41 Total: Ca- ) `13 Fuel Burned: co Fuel Purchased: Take off time: a a.ss Landing time: n kg Flight time: .g Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011418 CONFIDENTIAL EFTA 00122072 EFTA01267563 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ Larry Visoski cell Date: / jO. fro To: -nsr From: nUsP& Trip # al Pilot: t•-• \/% •nw.% Co-Pilot: D. l'ecrcto-tu Airframe: so.9 Landings: cc.s Total ca .3 Total Total Engine #1 sod Starts: 91 N1 cycles N2 cycles 1.L) + I (Cycles are recorded from aircraft IlDs panel) Total: .523 Engine #2 so.9 Starts: (ii N2 cycles N2 cycles 1.1 Total: 52:3 cia Fuel Burned: 1O-23 Fuel Purchased: Take off time: aloe Landing time: as as Flight time: 14-4 Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011419 CONFIDENTIAL EFTA_00122073 EFTA01267564 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ Larry Visoski cell Date: 8 /of, /la To: ii,pa PO. From: aw>,/ Trip # 2O Pilot: L. VierSec•ct Co-Pilot: ‘D, Ro-rwro— Airframe: qv.9 Landings: ea + 1.O + t Total Co .9 Total 63 Total Engine #1 qt,1 Starts: cto N1 cycles N2 cycles + 2 .0 + 1 (Cycles are recorded from aircraft IlDs panel) Total: s,9 qi Engine #2 qv.? Starts: it N2 cycles N2 cycles 227 Total: 5b.9 91 Fuel Burned: iq A3 Fuel Purchased: Take off time: 1-iss Landing time: az:O7> Flight time: Act al Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011420 CONFIDENTIAL EFTA_00122074 EFTA01267565 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ tarry Visoski cell Date: •3 104, lio To: AI me,/ From: reorr Trip # i9 Pilot: L. gisp-sKt Co-Pilot: b. RerrtActs_ Airframe: 47, Li Landings: toi Total LPL() Total 6a Total Engine #1 Li-TA Starts: t' N1 cycles N2 cycles + Is + (Cycles are recorded from aircraft IlDs panel) Total: 9(.7 Engine #2 qtq Starts: -n N2 cycles N2 cycles + Total: lir 7 9a Fuel Burned: it 0/ Fuel Purchased: Take off time: is 34, Landing time: rive Flight time: 1 -t-Sa Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011421 CONFIDENTIAL EFTA_00122075 EFTA01267566 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ Larry Visoski cell Date: % i cc, he, To: MIET-- From: Kittim Trip # v.‘ Pilot: l_. virsc-rs,‘-i Co-Pilot: b: ?CM CZ-A-- Airframe: J-ls, q Landings: co R. Total Total I Total Engine #1 $.4 Starts: -61 N1 cycles N2 cycles + 2 + 1 (Cycles are recorded from aircraft IIDs panel) Total: qi. q cip9 Engine #2 4s.4 Starts: Dr N2 cycles N2 cycles 9 .0 Total: '/7,V 151 Fuel Burned: 'Lisa Fuel Purchased: Take off time: Ian Landing time: I g-15/ Flight time: 4-1)-3 Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011422 CONFIDENTIAL EFTA_00122076 EFTA01267567 Shmitka Air, Inc. Flight Logs N722JE Serial it 760750 576C++ Larry Visoski cell Date: To: a-1 1- From: ppa-- Trip # 7 pilot:01. ;dos K, Co-Pilot. 1.4.56 ryS-Ame ElwomiG Airframe: 4 (4 3 Landings: s7 3 Total Total 0 Total Engine #1 y 51,3 Starts: 8 5 " Ni cycles N2 cycles + I I + 3 (Cycles are recorded from aircraft IlDs panel) Total: LiLC Engine #2 Lig .3 Starts: a 6- N2 cycles N2 cycles + • + 3 Total: 17 5 . e Fuel Burned: Fuel Purchased: Take off time: Landing time: Flight time: Passenger: Ze-e•to.) CNAD 800/6/E Passenger: Passenger: ( ,J;i6A.5 . "~RLgi:f9 Passenger: Passenger: Passenger: Passenger: Passenger: SDNY_GM_00011423 CONFIDENTIAL EFTA_OOI 22077 EFTA01267568 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750576C++ Larry Vlsosld cell Date: 5 To: iie/DBT Atm peit From: C6FA s/ec,„ey 672 Trip # Pilot: • I4so6 Co-Pilot: A. Airframe: Landings: 6-6 '3 Total 1543 Total 57 Total Engine #1 /4 0 Starts: /?/ N1cycles g1.3 N2 cycles 7 ct ,3 / (Cycles are recorded from aircraft IlDs panel) Total: 3 CS Engine #2 -41W,0 Starts: S Nt cycles N2 cycles 1-/a .3 ("2 ,3 1 Total: W3 EC Fuel Burned: //fO *51.P. 6-° Fuel Purchased: /4/1 ‘ifi2eArc$ Take off time: ,-P-i3pAt Landing time: 8:59/4n Flight time: 7Vph,20 Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: 72.5b/i/4-./- 4 e.t/F,D .7/e:i CONFIDENTIAL EFTA 00122078 EFTA01267569 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell eeresAy 5;4454, Date: 5715—A0 To: 06,Fif pt Ar - From: Cior-A Trip # /5 — Pilot: _L V_so5,4i Co-Pilot: /9. 17)47 Airframe: 0: 7 Landings: 56- Total 1 7, O Total Total Engine #1 43.-1 Starts: ,P.3 Ni cycles N2 cycles .3 + / (Cycles are recorded from aircraft IlDs panel) Total: 5/V, Engine #2 43,7 Starts: N2 cycles N2 cycles + .3 Total: 0 Fuel Burned: ,--20 /4i, Fuel Purchased: /00 64/6,1J.5 °3,Fer, Take off time: A55 pm Landing time: ,-;.• ICpm Flight time: 1.-/i A7t,i) Passenger: ( q/2 y emu) Passenger: ;4/ CY-4-0., AL 4Q4), in IA. ..1-QA)942.7 e( Passenger: (A)( Passenger: eZe2t4t-A.71-S Passenger: Passenger: PA( Passenger: v6/49P4,6 CO 1 „f4/-- NTIAL SDNY_GM_00011425 EFTA_00 I 22079 EFTA01267570 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750576C++ Larry Vlsoski cell 52444if .. ip ene • c..C.w at) "rai, W.0 Date: 5/151/0 To: /*Fil MAA) From: iSc.S"--T ‘.A. Trip # Pilot: 1 ./k05 ,4 Co-Pilot: ,q. loge/ Airframe: 7 Landings: 6 o + / Total 3-7 Total 55- Total Engine #1 q/, 7 Starts: ,c/,9Z Ni cycles N2 cycles + (Cycles are recorded from aircraft IlDs panel) Total: 43.7 ,k.3 Engine #2 if /' 7 starts: it, g N2 cycles N2 cycles a• 0 + Total: 4/ 3 1 69 29 = Fuel Burned: 4?7,6, IBS- Fuel Purchased: /1/ 6- A-z/0445 *FO-- - Take off time:/0 r•X•igill Landing time: ,}7o7,,,, Flight time: / 7L-5-5-soA.) Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Cd ,114 ‘ de-A-hez SONY_GM_00011426 fVfli AL EFTA_00122080 EFTA01267571 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 S76C++ Larry Visoski cell Date: 5- I5 - I0 To: 5 S- 1-: From: C 1-- Trip # /3 Pilot: )• VI 54, 5Z Co-Pilot: /. ,i-r 4c-2 Airframe: ?/-0? 6 Landings: 6-3 / Total / /' 17 Total 7 Total Engine #1 1-."0 • L Starts: / N1cycles N2 cycles + / / + l (Cycles are recorded from aircraft IlDs panel) Total: 9- (, Engine #2 (•;O • 0 Starts: 7 N2 cycles N2 cycles + + Total: /' Fuel Burned: i l 50 Fuel Purchased: is, / (pAzi..6/1.(41 6: irC Take off time: e / fln1 Landing time: 9: 4) art Flight time: / t 45. Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: Passenger: d5) SDNY_GM_00011427 CONFIDENTIAL EFTA 00122081 EFTA01267572 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell Date: 5 - I - IC) To: C L T /J c< PDL( Trip # Pilot:, S /2 Co-Pilot: at , Dcz.tfe-3 Airframe: 3 q, Landings: "3--- Total 546, Total i 3 Total Engine #1 3 Starts: 4'6' N1 cycles N2 cycles ,g (Cycles are recorded from aircraft IlDs panel) Total: 471° - ("•.-1 ‘ Engine #2 3'1, a— Starts: 6,6:, N2 cycles N2 cycles Total: 6 Fuel Burned: to13 Fuel Purchased: /d6" 6,'cL&A5 Take off time: 'i."330/1 Landing time: ,410,.) Flight time: fSI Passenger: Passenger: Passenger: (D lee-) Passenger: Passenger: Jiv4-7--- Passenger: Passenger: Passenger: 6,6) CONFIDENTIAL s' Gm-m°11428 EFTA 00122082 EFTA01267573 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell Date: '5 - /Li -/0 To: et- PM{ From: f-zixf Trip # / I Pilot: /50s < Co-Pilot: 4x,7)eff-e-c) Airframe: • ct Landings: C/ 72 , Total 1.,9 O1? Total 5J.- Total Engine #1 3g, (-I Starts: 79 N1 cycles N2 cycles .2 + (Cycles are recorded from aircraft IlDs panel) Total: 3f, g 60 Engine #2 1:34-. Starts: < N2 cycles N2 cycles :3 Total: ? Cie g 66; Fuel Burned: 3•Icpili Fuel Purchaseclieg<0/4 4/ Landing time: 3'3PPA Flight timerfric; Take off time: 3: l cpw1 Passenger: .) CoicA, Passenger: P/91 Passenger: f&ZILIE (S945) Passenger: Passenger: (PAS Passenger: Passenger: Pg-)( Passenger: 11 SDNY_GM_00011429 CONFIDENTIAL EFTA_00I 22083 EFTA01267574 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell Date: fr IN Ili To: --. ,k/ ,'A ."---) . to LIRA k; From: CL -7- Chia caeT nee. Trip # /0 Pilot:2 /nos/ Co-Pilot: 4;v4-Asi Airframe: 3 , / Landings: ,--Tin + Y + Total 3g• 9 Total Total Engine #1 72. ( Starts: c7k N1cycles N2 cycles (Cycles are recorded from aircraft IlDs panel) Total: -3 K. ct 79 Engine #2 31, I Starts: 0 N2 cycles N2 cycles , + / Total: Fuel Burned: Fuel Purchased: ,//7 ?_7.(0-610 /-1/1OA; S (_?. Take off time: 6:26 t4rk Landing time: 7 a C Flight time: -4- (4-5 Passenger: J 'oti Passenger: Passenger: IPA Passenger: • Passenger: < 4 _ Passenger: Passenger: Passenger: SDNY_GM_00011430 CONFIDENTIAL EFTA_00122084 EFTA01267575 Shmitka Air, Inc. Flight Logs N722JE Serial # 760750 576C++ Larry Visoski cell 'l- Date: 5 ild- 1 io To: e4,-/- dAgv,164/6-

EFTA00159483.pdf

DataSet-9 Unknown 227 pages

Plaintiff, JEFFREY EPSTEIN, Defendant. Reported By: Wendy Beath Notary Public, State of Florida Esquire Deposition West Palm Beach SUBJECT TO Larry Visoski 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 4 Suite 1650 5 6 7 On behalf of the Defendant: 8 9 10 11 On behalf of the Witness: 12 BRUCE REINHART, ESQUIRE 13 Suite 1400 14 15 ALSO PRESENT: 16 1220 N.W. 157th Avenue 17 18 19 20 21 22 23 24 25 SUBJECT TO Larry Visoski 1 2 3 4 5 WITNESS: 6 LARRY VISOSKI 7 BY MR. EDWARDS: 6 8 BY MR. CRITTON: BY MR. EDWARDS: 9 BY MR. CRITTON: 10 11 12 13 14 15 16 NUMBER 17 PLAINTIFF'S EX. 1 18 19 PLAINTIFF'S EX. 2 PLAINTIFF'S EX. 3 20 PLAINTIFF'S EX. 4 PLAINTIFF'S EX. 5 21 22 23 24 25 SUBJECT TO Larry Visoski 1 2 3 Deposition 4 Certified 5 the State 6 7 8 9 10 11 12 even 13 14 15 16 17 was produced 18 19 20 21 22 23 24 have to deal 25 SUBJECT Larry Visoski 1 that 2 3 and not 4 because 5 6 7 have 8 9 10 put on? 11 12 13 agree 14 we'll 15 16 these 17 understanding 18 19 20 file 21 22 I'm not 23 my office 24 25 what SUBJECT TO Larry Visoski 1 2 Thereupon, 3 4 having 5 and testified as follows: 6 7 8 BY MR. EDWARDS: 9 10 11 12 deposition taken 13 A. No. 14 15 you questions. 16 give us answers that 17 court reporter can 18 other verbal 19 when 20 your 21 pictures or 22 A. I understand. 23 24 this in 25 or not -- but I SUBJECT Larry Visoski 1 the question 2 the question. 3 4 5 6 Q. Right. 7 8 9 it's true. 10 11 12 BY MR. EDWARDS: 13 14 understand the question 15 don't 16 best of 17 it, I will. 18 A. Okay. 19 20 A. 22 23 24 25 A. SUBJECT Larry Visoski 1 Q. 2 A. 3 4 S 10 11 A. NES, LLC. 12 13 14 do the 15 16 A. Yes. 17 18 since 1991? 19 A. Yes. 20 21 22 that my check 23 24 them paying you? 25 SUBJECT TO Larry Visoski 1 helicopters. 2 3 you answer to at NES, LLC? 4 5 from 6 logistics 16 aircraft. 17 18 bonuses as well? 19 20 21 Christmas bonuses? 22 A. Yes. 23 24 A. No. 25 SUBJECT TO Larry Visoski 1 last time 2 180,000? 3 A. Last year. 4 5 6 salary 7 been 2008, last a 10 percent salary cut. 9 10 11 12 to take the salary cut? 13 14 15 16 throughout the country. 17 18 being 19 A. 200,000. 20 21 from NES, LLC? 22 A. Yes, sir. 23 24 bonus that 25 SUBJECT TO Larry Visoski 1 about? 2 3 4 5 have been 6 BY MR. EDWARDS: 7 Q. If 8 and I'm only 9 "Christmas bonus." 10 11 12 correct 13 only one and it 14 holidays? 15 A. Yes. 16 17 bonus? 18 A. I'd 19 haven't seen 20 was $10,000. 21 22 A. Yes. 23 Q. Okay. 24 25 accurate as SUBJECT TO Larry Visoski 1 2 A. Yes, sir. 3 4 roughly? 5 A. Right. 6 7 salary? 8 9 annual 10 know, it 11 five or $10,000 each 12 graduated, 13 14 start at 1991? 15 progression 16 making $200,000? 17 18 19 from 20 1991? 21 22 it that 23 24 LLC being the 25 SUBJECT TO Larry Visoski 1 my paycheck. 2 top of it. 3 Q. 4 would see, I'm assuming? 5 A. 6 the 7 column 8 Q. 9 heard the 10 A. 11 stood for. 12 that 13 Q. 14 NES, LLC is 15 pilot or 16 A. 17 Q. 18 different company that 19 Jeffrey 20 A. 21 Q. 22 pilot for 23 been a 24 Jeffrey Epstein 25 A. SUBJECT TO Larry Visoski 1 2 other 3 the best 4 5 6 approximately 7 8 Q. Okay. 9 10 Q. Yes. 11 A. I'm trying. 12 13 why I 14 A. Right. 15 16 A. Yes, sir. 17 18 approximately? 19 20 starting point. 21 22 - here ever 23 NES, LLC or 24 A. Yes. 25 SUBJECT TO Larry Visoski 1 A. Yes. 2 3 4 5 6 7 A. 1995-ish. 8 9 10 and 11 pool without 12 heater.• 13 14 15 16 17 18 Epstein? 19 A. Yes. 20 21 the 22 23 like on 24 25 that -- SUBJECT TO Larry Visoski 1 2 3 now. 4 A. Yes. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50200BCA028051XXXXMB AD 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 Anderson, RPR, CRR, FPR Services Office Job 8127542 3527-003 Page 1 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009676 EFTA00159483 October 15, 2009 2 BRADLEY J. EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Fort Lauderdale, Florida 33394 ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON & LUTTIER 303 Banyan Boulevard, Suite 400 West Palm Beach, Florida 33401 250 South Australian Avenue West Palm Beach, Florida 33401 CARA L. HOLMES, ESQUIRE Pembroke Pines, Florida 33028 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 RICHARD H. WILLITS, ESQUIRE (VIA TELEPHONE) RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 3527-003 Page 2 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009677 EFTA00159484 October 15, 2009 3 I NDEX DIRECT CROSS REDIRECT RECROSS 214 220 221 EXH IB ITS DESCRIPTION PAGE FLIGHT LOG BOOK (MARKED IN PREVIOUS DEPO) MESSAGE PAD 119 MESSAGE PAD 119 COMPLAINT 139 INMATE VISITOR LOG 161 3527-003 Page 3 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009678 EFTA00159485 October 15, 2009 4 PROCEED I NGS taken before Wendy Beath Anderson, Realtime Reporter and Notary Public in and for of Florida at Large, in the above cause. - - - MR. EDWARDS: We're going to put something on the record about -- well, we'll do it this way -- MR. REINHART: Do it at the end, after we get him -- whatever you want. It's your show MR. EDWARDS: Okay. There were don't think Mr. Willits is aware of this. There was a subpoena duces tecum for this witness, as well as the previous witness, which was another pilot, Dave Rogers, and that duces tecum was to bring the flight logs related from 1998 through 2005. What at the previous deposition were flight logs from 2002 through 2005, and now Mr. Reinhart has agreed to produce the remainder of the flight logs requested, those going from 1998 through 2002. MR. REINHART: Correct. They're pilot logs, not flight logs. There are other records we indicated are corporate records, and with those you with Mr. Critton. MR. CRITTON: However, with the proviso, too, 3527-003 Page 4 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009679 EFTA00159486 October 15, 2009 5 we're going to work out that these records are to be used within the confines of this litigation to be spread to the press or anyone else, they do contain confidential information as to who may have been on the plane and other records of Mr. Rogers, which but for the subpoena would been only available to the FAA or some other law enforcement agencies. MR. EDWARDS: Okay. Is that all you want to MR. CRITTON: Yes. MR. EDWARDS: I'm not saying I necessarily or disagree with you. That's something that deal with some other day. MR. CRITTON: Bruce, you'd better produce records, but there has to be some sort of before -- MR. REINHART: Correct. MR. EDWARDS: I won't do anything until you whatever you until we work whatever it is out in court. I'll say that on the record, that doing anything with the records outside of until some judge deals with it. MR. REINHART: And for the record, I'll adopt Mr. Critton said on this one limited occasion. 3527-003 Page 5 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009680 EFTA00159487 October 15, 2009 6 MR. EDWARDS: All right. (LARRY VISOSKI) been first duly sworn or affirmed, was examined THE WITNESS: Yes, I do. DIRECT EXAMINATION Q. Can you tell us your name for the record. A. Lawrence Visoski, Jr. Q. And Mr. Visoski, have you ever had your before? Q. Okay. Here's the process: I'm going to ask You're going to give us answers. Try to we all understand and that the take down, such as yes, no, or some answer that we can understand. It's easy we get in a casual conversation to nod or shake head, and the court reporter is not writing anything else. Q. The other thing is, and I've been accused of other depositions -- I don't know if it's true need to wait until you finish answering 3527-003 Page 6 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000968I EFTA00159488 October 15, 2009 7 and you need to wait until I finish asking A. So you're not allowed to interrupt me? Q. And you're not allowed to interrupt me. A. Like I just did? MR. CRITTON: Cara just snickered when you said you've been accused because she recognizes MR. EDWARDS: I don't know what the meaning of her snickering was. Q. But for what it's worth, if you don't or I've asked a bad question, I want you to guess. Give me the best answer to the your knowledge and if you need me to rephrase Q. Okay. Tell me your current address. Q. How long have you lived there? A. Approximately nine years. Q. Okay. Who do you live there with? 3527-003 Page 7 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_UXX0682 EFTA00159489 October 15, 2009 8 Q• Who's your employer right now? Q. How long has NES, LLC been your employer? A. I'm guessing. I'd say back 1991. I have to math, but 17, 18 years. Q. Has that been your only employer since 1991? Q. And has that been your only source of income Q. And what is NES, LLC? A. I don't really know. I mean, it's the company comes from. Q. What do you do for NES, LLC that results in A. I am chief pilot for the aircraft and 3527-003 Page 8 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009683 EFTA00159490 October 15, 2009 9 Q. And do you have a specific boss or somebody A. Several people would call to schedule flights the office, being it either Mr. Epstein or, you would just get a phone call and they would Q. Okay. Aside from Mr. Epstein, who else would would call to schedule flights? Q. Leslie who? Q. When's the last time you talked to Leslie A. Probably two weeks ago, three weeks ago. Q. And where is she currently? A. I believe in New York, is where I spoke to her Q. What's the telephone number you call to reach Q. And what address is Leslie Gruff at? A. Do you mean where the office is located? 3527-003 Page 9 of 227 TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009684 EFTA00159491 October 15, 2009 10 Q. And it's my understanding from other that there are also apartments in that building? Q. And Mr. Epstein either owns or leases or rents of those apartments. Is that your MR. CRITTON: Form; speculation. THE WITNESS: I'm only speculating. I don't -- to my understanding, I don't know. Q. Do you know other people that live in that A. Well, it would be myself, Dave Rogers -- well, you say "live,' explain. Q. When you're saying yourself and Dave Rogers -- A. See, we don't live there. I mean, we have -- when we would have a trip. Q. Okay. When you would fly up to New York and New York, the place where you would stay, is A. Yes, that's correct. Q. That's also a location you've indicated in that is the office for NES, LLC? 3527-003 Page 10 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTASO009685 EFTA00159492 October 15, 2009 11 Q. What floor or suite number is NES, LLC in? A. I believe -- well, I don't know that NES, LLC office there. I know that's where Leslie has the where I call. So I don't know for a fact office there. Q. And what suite number, then, would Leslie to answer that telephone number at A. I think it's III. Q. And when you stay at number or what apartment number do you stay Q. And how about Dave Rogers, where does he stay? A. I'm guessing, because it's been some time been there, 10B, but don't quote me on it. Q. Who are the other people in that building that know to stay there on a regular -- fairly regular A. I've seen people in the elevator that, you the airplane. Case in point, maybe but I don't know for a fact that she lives anybody else for that matter. Q. Okay. When you say you've seen 3527-003 Page II of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009686 EFTA00159493 October 15, 2009 12 A. I only assume she lives there. I don't know I'm trying to be honest and factual for So I couldn't honestly say if I knew she lived O. Where do you think lives? A. I would think she lives there. Q. You don't have a better location? A. I don't have another location. A. Not to my knowledge. I mean, I'd only be that people live in that building that -- you don't have any facts to prove that they actually I mean, I don't think you want me to guess. Q. Well, NES, LLC, would you say that the owner controller of that company is Jeffrey Epstein? MR. CRITTON: Form. THE WITNESS: I don't know that for a fact. Q. Jeffrey Epstein is somebody you've indicated worked for for 17 or 18 years, right? Q. And over the 17 or 18 years you've become with him as well, correct? MR. CRITTON: Form. THE WITNESS: I don't understand how you mean 3527-003 Page 12 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009687 EFTA00159494 October 15, 2009 13 Define that. Q. Well, more so than just a pilot that takes him A. That is my job. Q. Right. But you know him on a personal level had personal conversations that don't with flying from Point A to Point B; MR. CRITTON: Form. THE WITNESS: More specific, meaning we talk I mean, does that make you a personal Q. Have you ever gone to his house to eat? Q. Have you been to his New York home? Q. How many occasions have you been to his New MR. CRITTON: Object to form. THE WITNESS: We normally pick up luggage in the lobby, so it would probably be quite often. we depart out of New York, we stop by the pick up luggage and head to the aircraft. 3527-003 Page 13 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009688 EFTA00159495 October 15, 2009 14 Q. Other than picking up luggage, have you been home to visit or socialize with him? A. Not to socialize, no. Q. Have you been to his Palm Beach home? Q. To Mr. Epstein's Palm Beach house? Q. Have you been there? Q. Have you been inside? how many occasions have you been inside A. The same, as far as picking up luggage, and on a regular basis, you know, for a We wouldn't always go to the house to pick it made it easier for loading the it done prior to departure. Q. Is that the only reason that you have ever Beach home over the last 18 years, is Q. What other reasons have you gone there? A. I've set up several home theater equipments, 3527-003 Page 14 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009689 EFTA00159496 October 15, 2009 15 know, televisions and such. Q. Is that another hobby or job or something of Q. Does he pay you for that? A. Not any more than my salary. Q. What's your current salary? A. At this time, 180,000. Q. And what are you paid $180,000 to do? A. To manage his aircraft. Q. What does that entail? A. Scheduling maintenance. Anything that has to flight, whether it be weather, flight and distance to and from a location, any involved in running an operation that has Q. In addition to the 180,000, does he give you A. There have been Christmas bonuses. Q. Over the years, you mean, there have been Q. Is 180,000 the most he's ever paid you? Q. All right. Were you making -- when was the 3527-003 Page 15 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009690 EFTA00159497 October 15, 2009 16 that you were making an amount different than Q. That would be 2008? A. That would be correct. Yeah, we all took a cut, I don't know the exact date. It might have year. It was last Christmas we all took Q. Do you know why? A. Economic reasons. Q. And who told you that you were going to have A. Darren Indyke. Q. And did you ask for an explanation? A. He explained it was due to economic reasons Q. Okay. So in 2008, how much was -- were you paid by NES, LLC? Q. And is 200,000 the most that you've ever made Q. And on top of that $200,000, did you get a year as well? MR. REINHART: Which year are you talking 3527-003 Page 16 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009691 EFTA00159498 October 15, 2009 17 MR. EDWARDS: 2008. THE WITNESS: That year, I think we skipped Christmas bonuses that year. The last bonus might 2007. you ever got a bonus from Mr. Epstein deriving this from you using the term A. Holiday bonus. Q. -- am I correct to assume sorry. Am I to assume that if you got a bonus, there was was at the end of the year, around the Q. Okay. And how much was the 2007 holiday have to ask my wife, to be honest. I my paycheck in 27 years, so I believe it Q. And in 2007 you also made $200,000? A. With a question mark. I'm trying to be as I can, but yes. 3527-003 Page 17 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009692 EFTA00159499 October 15, 2009 18 Q. Something pretty close to that? Q. Okay. So with the bonus it was 210,000, Q. Okay. And how long were you making that A. Probably -- he was very religious about giving increases, so I would probably say 2006, you was -- we would get increment -- increases of year. So I would say 2006. So it you know, progressive. Q. Okay. Do you remember the progression if we Do you remember roughly what the was up through 2007/2008, when you were A. No, I wouldn't know the progression. Q. Okay. Do you remember what you were making and was NES, LLC the company paying you back in A. I don't know. I don't remember. Let me say way. I don't remember. Q. Okay. When -- how long do you remember NES, payer of your check? A. Personally, two years, because I've never seen 3527-003 Page 18 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00009693 EFTA00159500 October 15, 2009 19 So I don't even know what's written on the That would be something that only your wife You're right, since she probably wouldn't know answer either, because she's looking at the right and not the top column. Right. When is the first time that you had name NES, LLC, that company? Five, six years, and even questioned what it And I think to this day I couldn't answer honestly, what it stands for. Okay. But it's your understanding that the paying you for the work that you do as a maintain the planes for Jeffrey Epstein? To my understanding, yes. And back in 1991, do you know if it was a was paying you or if it was Epstein directly paying you? I don't remember. I mean, I don't. Okay. Throughout your career with -- as a Jeffrey Epstein, since 1991, has there ever time when you believe you were paid directly from personally versus some company? Not to my knowledge, no. 3527-003 Page 19 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009694 EFTA00159501 October 15, 2009 20 Q. Okay. So whether it was NES, LLC or some company, it was all of a sudden a company name, to of your knowledge? A. Exactly, yes. Q. And back in 1991, do you remember how much you were being paid that year? A. Fifty-five or 60,000, is maybe what I started. A. You're going back a long ways. Q. Your relationship goes back that far. That's chose that year. Q• Okay. Did you get bonuses even back that far? Q. And do you remember what your bonuses were A. 5,000. I mean, that was kind of the -- the Q. Okay. In addition to monitary bonuses, were gifts or any other type of compensation that Jeffrey Epstein provided you? Q. And is that over the span of the 18 years? 3527-003 Page 20 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009695 EFTA00159502 October 15, 2009 21 Q. Okay. Tell me what some of those items are. A. I remember one specifically was a pool heater. Q. Excuse me? A. A pool heater. Q. When was that? Q. Okay. Why did you get that? A. I had built a pool and I didn't have a heater he kind of laughed at me saying, "How can you have a a heater?" So he says, "You ought to get a Q. Where were you when you had that conversation? A. In the airplane. O. How did he know that you had built a pool? A. Just in general conversation. Q. You were having a conversation with Jeffrey Q. And this is something that was happening on airplane, this conversation? A. During the flight. Yeah, it would have been cruise or something. Q. Okay. When you say •during the flight," does 3527-003 Page 21 of 227 PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00009696 EFTA00159503 October 15, 2009 22 A. Again, you're going back a long ways. Q. I understand. We're talking about 1995 right

EFTA00413388.pdf

DataSet-9 Unknown 3 pages

From: George Delson To: Lesley Groff Subject: Re: Jeffrey Epstein Date: Thu, 10 May 2012 16:23:24 +0000 Attachments: JEE_Days_Present_5-10-12.xlsx Hi Lesley, Attached is a count of Jeffrey's days through May. If you need anything further, let me know. Ava The material contained herein is confidential, may be privileged, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited and may be unlawful. If you have received this communication in error, please notify us immediately, and destroy same and all copies thereof, including all attachments. US Treasury Department Circular 230 requires that we inform you that any federal tax advice contained in this communication (including attachments) is not intended or written to be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transactions or matter addressed herein. From: Lesley Groff To: George Delson Sent: Thursday, May 10, 2012 12:01 PM Subject: Re: Jeffrey Epstein super...let me know if anything else is weird! On May 10, 2012, at 12:00 PM, George Delson wrote: yes, got it. Thanks. The material contained herein is confidential, may be privileged, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited and may be unlawful. If you have received this communication in error, please notify us immediately, and destroy same and all copies thereof, including all attachments. US Treasury Department Circular 230 requires that we inform you that any federal tax advice contained in this communication (including attachments) is not intended or written to be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transactions or matter addressed herein. From: Lesley Groff To: George Delson Sent: Thursday, May 10, 2012 11:57AM 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! EFTA00413388 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- 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 EFTA00413389 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 <1 To: George Delson & Associates Delson George •r > Sent: Thursday, May 10, 2012 8:05 AM Subject: Jeffrey Epstein Good morning Maryellen. Could you please do a count of jeffrey's days so far this year. He is currently still in NY as the last flight log you have should state.. Please reply back and let me know when we can expect the count. Thank you, Lesley Sent from my iPhone EFTA00413390

EFTA00371563.pdf

DataSet-9 Unknown 1 pages

From: Larry Visoski To: "a ica Cc: Lesley Groff Subject: Re: Jeffrey Epstein Date: Tue, 08 Apr 2014 14:36:24 +0000 Great Greg, Welcome aboard ! Look fwd to seeing you again, All the best Larry Thx Lesley for the heads up. Sent from my iPhone > On Apr 8, 2014, at 10:13 AM, "Greg Wyler" < wrote: > Gregory Thane Wyler > I can go to necker anytime, 3:30pm departure is fine. • > He asked me to come to the house, which was my plan. • • > I land at 3:17 at JFK, and have a car waiting for me. Sitting up front and no bags so I am guessing I would be there around 4:15. > I can drive straight to teterboro if needed. Will email when I am in the car. On Apr 8, 2014 7:08 AM, Lesley Groff < > wrote: > Hello Greg...Jeffrey says you would like a ride tonight on his plane to St. Thomas...He also has kindly offered you a ride in his helicopter over to Branson's island tomorrow...He did want to make sure you know he will need you off island by at latest 4pm tomorrow and hope that works with your schedule.... > Wheels up from Teterboro tonight is 6pm...Did you and Jeffrey discuss riding together to Teterboro?...please let me know any details... > We will need your full name as it appears on your ID please for our flight log/pilot. • > Thank you, > Lesley > Assistant to Jeffrey Epstein EFTA00371563

EFTA00371336.pdf

DataSet-9 Unknown 2 pages

From: "Greg Wyler" To: Lesley Groff Subject: Re: Jeffrey Epstein Date: Wed, 09 Apr 2014 07:23:19 +0000 Is the WiFi available to guests here on the island? If so, what is the password? On Apr 8, 2014 2:19 PM, Lesley Groff wrote: tremendous. thanks On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote: > My cell is: > See you soon. > Original Message > From: Lesley Groff [mailto: > Sent: Tuesda April 08 2014 7:36 AM > To: > Cc: Lany 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 t onight... > 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 strai t to teterboro if needed. Will email when I am in the car. On Apr 8, 2014 7:08 AM, Lesley Groff wrote: EFTA00371336 >> 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 nee d 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 1 et 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 EFTA00371337

EFTA00622762.pdf

DataSet-9 Unknown 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. EFTA00622762 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". EFTA00622763

EFTA01112555.pdf

DataSet-9 Unknown 28 pages

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned counsel, hereby respectfully seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards to serve a privilege log that fully complies with Fla. R. Civ. P. 280(bX5), and an in camera review of the documents specified below, together with an award of attorney's fees and costs, and in support thereof would show as follows: SUMMARY OF ARGUMENT On or about February 23, 2011, Edwards, in response to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA01112555 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2,000) documents are privileged.' This is Edwards' second privilege log that blatantly fails to meet the requirements for a legally sufficient privilege log under Fla. R. Civ. P. 1.280 (bX5), as interpreted by the Fourth District Court of Appeal in TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). In addition, although the Special Master required a master list of names contained in the privilege log, a description of the recipients of the documents, and identification of the individuals who received blind copies, Edwards failed to provide the names of the individuals who were copied directly or who received blind copies, and many recipients are insufficiently identified only as "Attorneys at RRA," "Staff," and "RRA Personnel.i 2 Edwards' gross failure to comply with Fla. R. Civ. P. 1.280(6)(5) prevents the Plaintiff and the Court from determining whether Edwards has made any valid privilege assertions and results in a waiver of the privileges claimed. Edwards has not provided sufficient descriptions of the documents to determine if the privilege(s) claimed are valid. Finally, Edwards claims privileges that do not exist under Florida law. ARGUMENT I. REQUIREMENTS FOR A PRIVILEGE LOG The requirements for a privilege log in Florida are set forth in Fla. R. Civ. P. 1.280(bX5), which provides as follows (emphasis added): I Edwards' privilege log is being filed contemporaneous with the filing of the subject motion. For ease of reference, excerpts from the log are attached hereto as exhibits. 2 After Epstein's Motion to Compel was heard on August 4, 2010, the Bankruptcy Court entered at least four (4) orders directing Edwards to prepare a privilege log, the last of which required the privilege log to be completed by January 31, 2011. The first log, served on January 26, 2011, was in woeful noncompliance with the TIG requirements. On February 23, 2011, another log was served by Edwards which again patently failed to comply with T1G requirements. The February 23, 2011 log is the subject of the instant motion. 2 EFTA01112556 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Claims of Privilege or Trial Protection Materials. When a party withholds information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disposed in a manner that, without revealing information itself privileged, or protected, will enable other parties to assess the applicability of the privilege or protection. The key case in the Fourth District construing Fla. R. Civ. P. 1.280(b)(5) is TIG Ins. Corp., 799 So. 2d 339, in which the Fourth District Court of Appeal denied a petition for a writ of certiorari seeking review of an order requiring TIG, the homeowner's insurer, to produce documents for which objections on the basis of attorney-client and work-product privileges were made. The Fourth District noted in TIG that Rule 1.280(b)(5) is identical to its federal counterpart, Fed. R. Civ. P. 26(bX5), whose Advisory Committee Notes state that "to withhold materials without such notice is contrary to the rule, subjects the party to sanctions under rule 37(b)(2) and may be viewed as a waiver of the privilege or protection." 799 So. 2d at 340. The TIG court further observed that Local Rule 26.1(GX3)(b), of the United States District Court, Southern District of Florida, spelled out the requirements for a valid privilege log, id. at 341: Where a claim of privilege is asserted in objecting to any interrogatory or document demand, or sub-part thereof, and an answer is not provided on the basis of such assertion: (i) The attorney asserting the privilege shall in the objection to the interrogatory or document demand, or sub-part thereof, identify the nature of the privilege (including work product) which is being claimed and if the privilege is being asserted in connection with a claim or defense governed by state law, indicate the state's privilege rule being invoked; and 3 EFTA01112557 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG (ii) The following information shall be provided in the objection, unless divulgence of such information would cause disclosure of the allegedly privileged information: (A) For documents: (1) the type of document; (2) general subject matter of the document; (3) the date of the document; (4) such other information as is sufficient to identify the document for a subpoena duces tecum, including, where appropriate, the author of the document, the addressee of the document, and, where not apparent, the relationship of the author and addressee to each other. The Fourth District also quoted with approval from Abbott Laboratories v. Alpha Therapeutic Corp., 2000 U.S. Dist. LEXIS 20834, at *13 (N.D. III. Dec. 14, 2000), in which the court stated that a privilege log should: describe the document's subject matter, purpose for its production, and a specific explanation of why the document is privileged or immune from discovery. These categories, especially this last category, must be sufficiently detailed to allow the court to determine whether the discovery opponent has discharged its burden of establishing the requirements expounded upon in the foregoing discussion. Accordingly, descriptions such as 'letter re claim,' analysis of claim,' or 'report in anticipation of litigation'--with which we have grown all too familiar--will be insufficient. This may be burdensome, but it will provide a more accurate evaluation of a discovery opponent's claims and takes into consideration the fact that there are no presumptions operating in the discovery opponent's favor. Any failure to comply with these directions will result in a finding that the plaintiff-discovery opponents have failed to meet their burden of establishing the applicability of the privilege. (Citations omitted) Thus, a party invoking a privilege "must...provide sufficient information to enable other parties to evaluate the applicability of the claimed privilege or protection." Hoot Winc, LLC v. RSM McGladrey Fin. Process Outsourcing, LLC, 2009 U.S. Dist. 4 EFTA01112558 Epstein v. Rothstein and Edwards Case No. 502009CA040800,OOCXMWDiv. AG LEXIS 103045, at •9 (S.D. Cal. Nov. 4, 2009) (quoting Advisory Committee Notes to Rule 26(bX5)).3 TIG, 799 So. 2d at 341. II. EDWARDS' PRIVILEGE LOG VIOLATES FLA. It. CIV. P. 1.280(bX5) AND THE TIC REQUIREMENTS Edwards' privilege log clearly violates the requirements of Florida law, and is insufficient on its face, as first evidenced by Edwards' one hundred and ninety-one (191) attempts to shield documents from or to an unnamed "confidential source," especially for documents described as "Litigation Strategy." See Composite Exhibit A as an example of this frivolous claim. Second, and no less outrageous, is Edwards' use in approximately one hundred (100) log entries in the "to" and "from" categories of the generic terms "attorney and staff," "litigation," "RRA personnel," and "unknown staff attorneys at RRA." Such generic terms do not meet the TIG requirements. See Composite Exhibit B for examples. Edwards' numerous references to unnamed "Attorneys at RRA" are patently inappropriate, if not disingenuous, preventing in each instance a necessary determination as to whether Edwards has validly invoked a privilege. Without identification of the particular RRA attorney as the sender or recipient, it is impossible 3 See also Evans v. United Fire & Cas. Ins. Co., 2007 U.S. Dist. LEXIS 58578, at •9 (ED. La. Aug. 9, 2007) ("United has provided a privilege log, but it is insufficient on its face. Rule 26(bX5) requires such a log to 'describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection.' "); Caplan v. Fellheimer Eichen Braverman & Kaskey, 162 F.R.D. 490, 492 (ED. Pa. 1995) (party's failure to explain nature of the assertedly privileged communication precluded court from determining whether privilege applied); Harper v. Auto-Owners Ins. Co., 138 F.R.D. 655, 664 (S.D. Ind. 1991) (requiring the log to list, for each separate document, the authors and their capacities, the recipients (including copy recipients) and their capacities, the subject matter of the document, the purpose for its production, and a detailed, specific explanation of why the document is privileged or immune from discovery). 5 EFTA01112559 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG to determine whether Edwards can properly shield the materials from disclosure. Such non-disclosure strongly suggests a deliberate effort by Edwards to prevent the disclosure of documents to and from Scott Rothstein and other employees at RRA (including other RRA attorneys, such as Russell Adler, who was implicated by Scott Rothstein himself in recent sworn deposition testimony) involved in the massive fraud at RRA. Third, Edwards' privilege log fails to indicate whether the documents were copied or distributed to third parties, or whether blind copies were sent to third parties, which the Special Master specifically required. See Privilege Log generally. Fourth, the privilege log fails to indicate whether the materials contain attachments. "Where a privileged document has attachments, each attachment must individually satisfy the criteria for falling within the privilege. Merely attaching something to a privileged document will not, by itself, make the attachment privileged." Leonen v. Johns-Manville, 135 F.R.D. 94, 98 (D.N.J. 1990). Edwards is not entitled to invoke a privilege with respect to attachments which themselves have not been described at all and lack the specificity required to determine whether any privileges apply. It is hard to fathom that not one of these documents listed in the log did not have an attachment. The Court should order that the attachments be produced. Fifth, it is readily apparent that the privilege log fails to adequately describe over two hundred (200) assertedly privileged documents with descriptions such as "in re Epstein," "litigation strategy," "Meeting" and "FYI." Such shorthand, cryptic labels, with no description whatsoever of the content of the materials, do not permit Epstein or the Court to begin to evaluate the applicability of the privileges claimed by Edwards. TIG, 799 So. 2d at 341 6 EFTA01112560 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG (quoting Abbott Labs, 2000 U.S. Dist. LEXIS 20834, at *13)("fDlescriptions such as 'letter re claim', 'analysis of claim' or 'report in anticipation of litigation'.. . will be insufficient."). Sixth, Edwards' privilege log does not disclose the type of documents that are assertedly privileged — e.g., email, letter, memo. See Privilege Log generally. In sum, Edwards' privilege log is grossly inadequate and in blatant violation of Rule I .280(b)(5), precluding Epstein and the Court from evaluating the applicability of the numerous privileges claimed. III. EDWARDS HAS NO VALID PRIVILEGE CLAIMS A. Edwards Has No "Confidential Source" Privilege Edwards objects to producing hundreds of pages of documents from or to a purportedly "confidential source." See examples in Composite Exhibit A. There are approximately one hundred and ninety-one (191) entries in the privilege log that cite a "confidential source." There is no Florida law, however, that gives Edwards the right to assert a privilege based upon "a confidential source." Indeed, a "confidential source" privilege applies only with respect to reporters protecting their sources. See, e.g., CBS v. Jackson, 578 So.2d 698, 700 (Fla. 1991) (journalists have a qualified privilege against revealing confidential sources of information). Edwards is not a reporter. Therefore, as a matter of settled law, Edwards has no valid objection based upon a "confidential source" privilege. The Court should order these documents produced forthwith. 7 EFTA01112561 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMR/Div. AG B. "Privacy Rights" Edwards objects to the production of approximately nine hundred and thirty (930) documents on the ground that they are "protected by privacy rights." See Privilege Log generally and examples in Composite Exhibit C. Remarkably, Edwards claims that approximately 75% of the documents listed are shielded from discovery by unspecified "privacy rights." His objections, however, do not identify the specific "privacy" privilege or describe the person whose privacy interests are assertedly at stake or the nature of the privacy interest at stake. Such amorphous "privacy rights" are non-existent under Florida law. No valid privilege can be raised in an attempt to protect purely generic "privacy rights." Section 90.501, Fla. Stat., expressly states in relevant part that "[e]xcept as provided by this chapter, any other statute, or the Constitution of the United States or of the State of Florida, no person in a legal proceeding has a privilege to . . . (3) [defuse to produce . . . any writing." Neither the Florida Evidence Code, other Florida statutes, or the Constitution, recognizes a privilege for generic "privacy rights" or precludes the production of documents in a legal proceeding based upon a general right of privacy. See La Roche v. Wainwright, 599 F.2d 722, 726 (5th Cir. Fla. 1979) (rejecting "fourteenth amendment rights to privacy" to protect marital relationship: "[W]e see no persuasive reason to extend the right of privacy, based as it is on "penumbras and emanations" of other more explicit constitutional rights, to evidentiary matters protecting marital relationships, long thought to be uniquely within the regulatory province of the individual states."). In sum, Edwards cannot hide behind a sham privilege based on "privacy rights." 8 EFTA01112562 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG C. Attorney-Client Privilege Does Not Apply to Non-Attorney-Client Communications Edwards invokes the attorney-client privilege with respect to thousands of pages of documents listed in 120 pages of his 159-page privilege log. See Privilege Log generally. Significantly, the log describes only three of these documents as attorney-client communications. See Exhibit O, Bates 02546-02547, 02809-02810, 02807-02808. There is no description or information provided by Edwards to suggest that any of the other documents claimed to be subject to the attorney-client privilege, actually arc. The following examples demonstrate Edwards' utterly cavalier and improper invocation of the attorney client privilege: 1) Priscilla Nascimento to "Attorneys at RRA" re: reserving a conference room; and 2) Beth Williamson to Bradley Edwards re: "Discussions about Brad's recovery." See Composite Exhibit E. The attorney-client privilege applies only to communications between counsel and client and cannot be asserted to block the discovery of communications that are not identified as attorney-client communications. See, e.g.,, §90.502, Ha. Stat., Skorman v. Hovnanian of Florida, Inc., 382 So. 2d 1376, 1378 (Fla. 4th DCA 1980). Accordingly, no attorney-client privilege attaches to communications that have not been specifically identified by Edwards as attorney-client communications. In addition, with respect to the numerous communications or documents to which Edwards has asserted the attorney-client privilege, Edwards must establish all of the following elements: (1) the asserted holder of the privilege is or sought to become a client; (2) the person to whom the communication was made (a) is a member of a bar of a court, or his subordinate, and (b) in connection with this communication is acting as a lawyer; (3) the communication relates to a fact of which the attorney was informed (a) by his client (b) without the presence of strangers 9 EFTA01112563 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG (c) for the purpose of securing primarily either (i) an opinion on law or (ii) legal services or (iii) assistance in some legal proceeding, and not (d) for the purpose of committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client. See § 90.502, Fla. Stat.; State v. Rabin, 495 So. 2d 257, 60 (Fla. 3d DCA 1986). The attorney-client privilege does not apply to communications between an attorney and a third party, or a person who is not a client. See State v. Rabin, 495 So. 2d at 260 (attorney-client privilege did not attach to attorney's communication with client's ex-wife). The attorney-client privilege is waived if the client voluntarily discloses the substance of the communication. See § 90.507, Fla. Stat.; Delap v. State, 440 So. 2d 1242, 1247 (Fla. 1983) ("[W]hen a party himself ceases to treat the matter as confidential, it loses its confidential character."). Edwards' woefully inadequate privilege log does not provide sufficient information to the enable Epstein and the Court to determine the applicability of the attorney-client privilege to thousands of communications listed in the privilege log. The alleged client involved is not disclosed with respect to each communication. The purpose of the document is not described. the The names of all recipients are not disclosed, preventing a determination as to whether attorney-client privilege was waived. No information is provided which would enable the Court and Epstein to determine whether the communications were intended to be disclosed to third parties or did not involve the giving of legal advice, in which case there is no privilege. See, e.g., Watkins v. State, 516 So. 2d 1043, 1046 (Fla. l g DCA 1987). D. The Work Product Privilege Cannot Be Determined From Edwards' Privilege Log Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), explained what is covered by the work product privilege: I0 EFTA01112564 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Mhose documents, pictures, statements and diagrams which are to be presented as evidence are not work products anticipated by the rule for exemption from discovery. Personal views of the attorney as to how and when to present evidence, his evaluation of its relative importance, his knowledge of which witness will give certain testimony, personal notes and records as to witnesses, jurors, legal citations, proposed arguments, jury instructions, diagrams and charts he may refer to at trial for his own convenience, but not to be used as evidence, come within the general category of work product. The work product doctrine protects documents and papers of an attorney or a party prepared in anticipation of litigation, regardless of whether they pertain to confidential communications between attorney and client. Fla. IL Civ. P. 1.280(bX2). See Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). Work product is a qualified immunity from discovery. See DeBartolo-Aventura, Inc. v. Hernandez, 638 So. 2d 988 (Fla. 3d DCA 1994). The work product privilege does not extend to materials intended for use as evidence at trial. Northup v. Acken, 865 So. 2d 1267 (Fla. 2004). Work product falls into two categories: I) "fact" work product consisting of factual information pertaining to a client's case that is prepared in anticipation of litigation or for trial by another party; and 2) "opinion" work product, which includes all attorney's mental impressions, opinions or conclusions about a client's case. The former is discoverable upon a showing of (a) need for the materials to prepare the party's case, and (b) inability to obtain the substantial equivalent of such materials without undue hardship. See, e.g., Metric Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003). The latter is subject to nearly absolute immunity. See, e.g., Smith v. Ma. Power & Light Co., 632 So. 2d 696 (Fla. 3d DCA 1994). A trial court is instructed "to make particularized findings in support of its determination of which of the documents are, or are not, subject to the work product privilege." Dismas 11 EFTA01112565 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Charities, Inc. v. Dabbs, 795 So. 2d 1038, 1039 (Fla. 4th DCA 2001). The party asserting the privilege must prove that the materials constitute work product. See, e.g., Prudential Ins. Co. of Am. v. Fla. Dept of Ins., 694 So. 2d 771, 773-74 (Fla. 2d DCA 1997) (objecting party provided affidavits stating that the documents were prepared in anticipation of litigation). See, e.g., Lloyds Underwriters of London v. El-Ad Villagio Condo. Ass 'n, 976 So. 2d 28 (Fla. 4th DCA 2008) (discovery order quashed where no in camera inspection was made). Thus, a trial court is not required to protect materials from discovery if a party makes no affirmative showing, and only makes "a blanket statement that these items were prepared in anticipation of litigation and are protected from disclosure without presenting evidence to support the claim." Wal-Mart Stores, Inc. v. Weeks, 696 So. 2d 855, 856-57 (Fla. 2d DCA 1997). Once the party seeking the documents challenges non-production, the burden shifts to the opposing party to establish that the materials were prepared in anticipation of litigation in which case they are discoverable upon a showing that the former has need of the materials and cannot obtain the equivalent without undue hardship. See, e.g., Tampa Med. Assoc., Inc. v. Estate of Torres, 903 So. 2d 259, 263-64 (Ha. 2d DCA 2005). Given the numerous violations on the face of Edwards' privilege log, including no descriptions of the types of communications, inadequate descriptions of the content of the communications, and no references to particular clients, Epstein and the Court have no way to determine whether the work product privileges claimed arc fact or opinion work product. See Privilege Log generally. It is essential that sufficient information be provided by Edwards to distinguish between fact and opinion work product. The need to ascertain which "facts" arc 12 EFTA01112566 Epstein v. Rothstein and Edwards Case No. 502009CA 040800XXXXMB/Div. AG being protected is particularly critical given the testimony by Scott Rothstein of extensive fraud at RRA, and Epstein's right to discoverfact work product upon a showing of need. E. Pooled, Joint Defense or Common Litigation Interest Cannot Be Determined from the Privilege Log Litigants who share "unified interests" may exchange privileged information to prepare their case without losing the benefit of the attorney-client interest pursuant to the "joint defense," "common interest" or "pooled information" exception. Visual Scene, Inc., v. Pilkington Bros., 508 So. 2d 437, 440 (Fla. 3d DCA 1987). The exception has been recognized in the case of co-defendants, co-parties to potential litigation, members of a class of plaintiffs pursuing separate suits, and defendants in separate actions. Id (citations omitted). However, the joint defense privilege, more properly identified as the "common interest rule," see generally Capra, The Attorney-Client Privilege In Common Representations, 20 Trial Lawyers Quarterly, Summer 1989, at 20, has been described as an extension of the attorney client privilege, Waller v. Financial Corp. of Am., 828 F.2d 579, 583 n.7 (9th Cir. 1987). It serves to protect the confidentiality of communications passing from one party to the attorney for another party where a joint defense effort or strategy has been decided upon and undertaken by the parties and their respective counsel. See United States v. Bay State Ambulance and Hosp. Rental Serv, 874 F.2d 20, 28 (1st Cir. 1989). Only those communications made in the course of an ongoing common enterprise and intended to further the enterprise are protected. Eisenberg v. Gagnon, 766 F.2d 770, 787 (3d Cir.), cert. denied 474 U.S. 946, 106 S. Ct. 342, 88 L. Ed. 2d 290 (1985); Matter of Bevil!, Bresler & Schulman Asset Management Corp., 805 F.2d 120 (3d Cir. 1986). United States v. Schwimmer, 892 F.2d 237, 243 (2d Cir. N.Y. 1989) (emphasis added). Thus, "parties seeking to invoke the exception must establish that they 13 EFTA01112567 Epstein v. Rothstein and Edwards Case No. 502009CA0408003COMMB/Div. AG agreed to engage in a joint effort and to keep the shared information confidential from outsiders." Ken's Foods, Inc. v. Ken's Steak House, Inc., 213 F.R.D. 89, 93 (D. Mass. 2002). See also United States v. Sawyer, 878 F. Supp. 295, 297 (D. Mass. 1995) (despite similar interests between employer and employee, there was insufficient evidence that communications were made during the course of a joint defense effort; proponent could not establish the time frame of the purported agreement or the acts creating and/or terminating the agreement). Edwards' privilege log does not establish that the communications listed were made during the course of an "ongoing common enterprise," does not establish relevant time frames, and does not establish that "a joint defense effort or strategy has been decided upon and undertaken by the parties and their respective counsel." North River Ins. Co. v. Columbia Casualty Co., 1995 U.S. Dist. LEXIS 53, at •7 (S.D.N.Y. Jan. 5, 1995) (citation and quotation omitted). Given the critical gaps in Edwards' privilege log, it is impossible to determine whether Edwards can properly invoke the "common interest" doctrine to preclude discovery. IV. EDWARDS' FAILURE TO SUPPLY AN ADEQUATE LOG WAIVES THE PRIVILEGES CLAIMED AND SUPPORTS SANCTIONS AGAINST EDWARDS It is settled that the failure to supply a privilege log which complies with Florida law results in the waiver of a privilege under Florida law. TIG, 799 So. 2d at 341 ("Any failure to comply with these directions will result in a finding that the plaintiff-discovery opponents have failed to meet their burden of establish[ing] the applicability of the privilege."). The TIG court noted that Rule 1.280(B)(5) "uses mandatory language, and federal courts have found waiver where the federal rule was violated." Id. (citing cases). The TIG court concluded that there was 14 EFTA01112568 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG no departure from the essential requirements of the law in compelling production based upon a privilege waiver: "Because the trial court did not have the benefit of specific descriptions of the documents, we assume that the court found a waiver." Id. at 342. See also Century Bus. Credit Corp. v. Fitness Innovations & Techs., Inc., 906 So. 2d 1156, 1157 (Fla. 4th DCA 2005) (the court denied a petition for certiorari directed to an order finding a waiver of privilege in regard to the production of documents because the petitioner filed a privilege log which was "completely inadequate"); Kaye Scholer UP v. Zalis, 878 So. 2d 447, 449 (Fla. 3d DCA 2004) (the purpose of the privilege log requirement is "to identify materials which might be subject to a privilege or work product protection so that a court can rule on the 'applicability of the privilege or protection' prior to trial...Failure to comply with the requirements of Rule 1.280(6)(5) results in the waiver of any attorney-client and work-product privileges."); Omega Consulting Group v. Templeton, 805 So. 2d 1058, 1060 (Fla. 4th DCA 2002) (noting that where a privilege log "filed by the corporations did not contain sufficient detail to comply with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)," the attorney-client privilege may be waived). Edwards has had ample opportunities to file a proper privilege log, and has declined to do so. Given his blatant violation of Rule 1.280(bX5), the magnitude of the deficiencies in his privilege log, and his cavalier invocation of numerous clearly inapplicable and/or non-existent privileges, this Court should enter an order finding a waiver and requiring production of the documents requested. See TIG. In the alternative, the Court should compel Edwards to produce a privilege log that strictly complies with TIG and the requirements of Rule 1.280 in order that Epstein and the Court can reasonably determine whether any valid privileges have been asserted and were not waived. 15 EFTA01112569 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG At a minimum, and as soon as convenient, the Court should conduct an in camera inspection of the documents referenced in In 20, 22-4 of the Corrected Second Amended Complaint and determine whether any of the privileges asserted by Edwards to block the production of these highly relevant materials are valid or have been waived. These materials — approximately thirty (30) emails — were sent to or from Edwards during the critical period of May to October, 2009, when the Ponzi scheme was imploding. The critical nature of these documents is vividly demonstrated by Rothstein's testimony during his recent deposition that he had asked Edwards or Adler to specifically set aside a flight manifest for an Epstein private jet. (Tr. Rothstein Depo 12/21/11 at 2278). Rothstein further testified that he showed boxes with Epstein files to the Discala investors in his office, disclosing the actual names of the parties "as a way of me attempting to induce them to invest further." (Tr. Rothstein Depo 12/20/11 at 1917; see also Tr. 12/21/11 at 2278). Rothstein explained with regard to Edwards' lawsuits that "this was a big ticket because there was the defendant and he's a wealthy guy" and was associated with public figures who did not want their names dragged through the mud. (Tr. Rothstein Depo 12/21/11 at 2283).4 Thus, because the documents specifically referenced in the Corrected Second Amended Complaint are critical to the continued deposition of Rothstein in June, 2012, an in camera inspection should be conducted of those documents prior to that time, although entries 4 It is important to note that in light of Rothstein's testimony, potentially relevant during this time frame — including, Edwards to "Attorneys at RRA" re: "Flight logs for Epstein," Bradley Edwards to "Attorneys at RRA" re: "Subpoena Clinton," Bradley Edwards to "Attorneys at RRA" re: "Investigation Epstein's planes," Bradley Edwards to "Attorneys at RRA" re: "Epstein meeting," and Priscilla Nascimento to ""Attorneys at RRA" re: "Epstein's Conference Room Reserved" — raise disturbing questions as to whether the "Attorneys at RRA" designation used by Edwards in his log is meant to disguise communications to Rothstein and others involved in the Ponzi Scheme. 16 EFTA01112570 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein does not hereby waive the right to an in camera review with respect to any of the other materials referenced in the Privilege Log. Finally, the actual prejudice to and impact on Epstein by Edwards' willful and continued non-compliance is palpable. Epstein has been prejudiced because he has not been able to conduct critical discovery necessary for the prosecution of his claims, and necessary for opposition to Edwards' summary judgment motion. Epstein has spent tens of thousands of dollars in attorney's fees trying to obtain the requested documents from Edwards and address privilege log issues. Sanctions should be imposed on Edwards to prevent unfair prejudice to Epstein and to insure the integrity of the discovery process. See Aztec Steel Company v. Florida Steel Corp., 691 F. 2d 480, 482 (11th Cir.1982). In sum, pursuant to Fla. R. Civ. P. 1.280, this Court should enter an Order finding that Edwards' privilege claims are waived, requiring Edwards to produce the documents requested by Epstein, and requiring Edwards to pay the reasonable expenses incurred by Epstein, including attorney's fees, costs, payments to the Special Master caused by Edwards' failure to provide a timely and legally sufficient privilege log, and granting such other and further relief as the Court deems necessary and proper. Respectfully sub(fitted, , 4Ackerman, .,. ), lorida Bar No. 235954 Jr. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff Jeffrey Epstein 17 EFTA01112571 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG and Christopher E. Knight Florida Bar. No. 607363 FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for PlaintiffJeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail on this 8th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Blvd., Suite 700, Fort Lauderdale, FL 33301. 1 ) oseph L. Ackerman, Jr. 18 EFTA01112572 Privilege Log — Dated 2-23-2011 farmer. Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE TO MOM DESCRIPTION OBJECTION discovery of admissible evidence 05693-05695 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05698 08/21/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05706-05709 05/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05720-05721 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05738-05739 05/29/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05743-05745 05/29/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to tbble i 3r discovery of admissible evidence n 05754 08/03/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence C 05759-05762 06/01/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence rn 05765-05768 06/23/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to t21 discovery of admissible evidence 05771-05773 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 05777.05779 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 05784-05786 06/03/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05791-05794 06/03/2009 Bradley Edwards Confidential Source Additional Information RE: W/P Priv.; not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence 05803 07/22/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05836-05837 07/08/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05842-05843 07/08/2009 Bradley Edwards Confidential Source Providing New Witnesses W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 49 EFTA01112573 Privilege Log — Dated 2-23-2011 Farmer, Jaffe. Weissing, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 05848 07/28/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05852-05853 07/29/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05857.05858 07/31/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to discovery of admissible evidence 05952-05953 08/25/2009 Bradley Edwards Confidential Source Litigation Strategy W/P Priv.; not reasonably calculated to lead to

EFTA00559527.pdf

DataSet-9 Unknown 1 pages

From: To: Subject: Re: Where are y'all? Date: Wed, 10 Nov 2010 13:49:04 +0000 I actually don't have the confirmation. Sultans office booked it for us and I only have our confirmation code On Nov 10, 2010, at 3:40 PM. wrote: > Ok super. So sounds like I will only need air france whenever you get to it! Thx > Original Messa e > From: > To: > Sent: Wed Nov 10 08:10:11 2010 > Subject: Re: Where are y'all? > We took private from Dubai to Turkey, and are taking Air France today from Istanbul to Paris. Sultan is dropping us off in the private plane from Antalya to Istanbul. > On Nov 10, 2010, at 2:44 PM, > Ok great. I'm glad that worked out. Sounds like u r taking the air france flight. Can u do me a favor and email me JE's etickets (if they exist...maybe he took private to turkey??) But I need for my flight log binder for JE! But any record of a ticket is good. I have the open skies to paris and the etihad to abu dhabi. Thanks! >> Original Messa e----- » From: » To: >> Sent: Wed Nov 10 07:41:15 2010 >> Subject: Re: Where are y'all? >> We are flying to paris from turkey! Landing in paris at 9:25pm tonight. >> On Nov 10, 2010, at 2:38 PM, liMia> wrote: >>> Are you flying to Paris today from Turkey? Just trying to keep up! EFTA00559527

EFTA02108910.pdf

DataSet-10 Unknown 2 pages

To: Greg Wyle From: Lesley Gro Sent Tue 4/8/2014 6:18:45 PM Subject Re: Jeffrey Epstein tremendous. thanks On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote: > My cell is• > see you soon. • Original Message > From: Lesley Groff > Sent: Tuesda , A ril 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. >> EFTA_R1_00727505 EFTA02108910 » Thank you, » Lesley » Assistant to Jeffrey Epstein >> > > EFTA_R1_00727506 EFTA02108911

EFTA00418188.pdf

DataSet-9 Unknown 1 pages

From: Lesley Groff To: George Delson Subject: Re: Jeffrey Epstein Date: Tue, 13 Mar 2012 13:41:44 +0000 thank you! On Mar 13, 2012, at 9:39 AM, George Delson wrote: Hi Lesley: Yes I did receive it. Thanks. Mary Ellen The material contained herein is confidential, may be privileged, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is prohibited and may be unlawful. If you have received this communication in error, please notify us immediately, and destroy same and all copies thereof, including all attachments. US Treasury Department Circular 230 requires that we inform you that any federal tax advice contained in this communication (including attachments) is not intended or written to be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transactions or matter addressed herein. From: Lesley Groff To: George George Sent: Monday, March 12, 2012 11:49 AM Subject: Jeffrey Epstein Hello Mary Ellen. Hope you had a nice weekend. I just faxed you over Jeffrey's most recent flight log for March 10th. Please confirm receipt Thanks, Lesley EFTA00418188

EFTA00590749.pdf

DataSet-9 Unknown 10 pages

BOI ES SCHI LLER t FLEXNER LLP 401 EAST LAS OLAS BOULEVARD • SUITE 1200 • FORT LAUDERDALE. FL 33301 22 • PH 954 • 254 356 0022 6 MCC $1 5 rid C•FA X, t sci. snictawIevAThstlin.com January 30, 2017 Confidential Sealed Filing VIA EMAIL & FACSIMILE: Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 SweetNYSDChambersQnysd.uscourts.gov Re: v. Maxwell, Case No.: 15-cv-07433-RWS Dear Judge Sweet, This is a reply letter in support of Ms. letter motion to allow for the newly- discovered witness, I to be called as a witness at trial because she can testify about Defendant's involvement in Epstein's sex trafficking ring based on first-hand experiences and first-hand observations. Defendant Violated Rule 26 By Failing To Disclose This Critical Witness Defendant argues that Ms. is somehow to blame for the fact tha is only now being discussed as a witness in this case. But Ms. only recently learned about this witness because Defendant failed to properly disclose her months earlier. In her response, Defendant does not address the fact that Ms. and Ms. Maxwell know each other. Indeed, Defendant does not address the fact that and she s nt time together on Mr. Epstein's private island, as reflected in the flight logs showing flying to and from the island (where Ms. Maxwell was present): _-i—g_ _-]21_1•z' lisstx91`4"ri V.) De _AU)/ i t le12.;?-apz" 4---i--' .rav\ tit lb I GAISMO NMOcl•Tal 1 6 -WC 11-ST I Mn UM t' 1‘ aiti_a_j_..111 all I' " 1-its—Ad Cr e. MT f ilea) Gflight log, on December 10, 2006 (Flight #19 Lew from EWR (Newark, NJ) to TIST (USVI) with Jeffrey E stcin, On December 14, 2006 (Flight #1920), flew from TIST (USVI to (Newark, NJ) with Jeffrey Epstein and . See 07139. Ms. was also flown commercially to Jeffrey Epstein's Island several times. Defendant was obligated under Rule 26 to includ in her Rule 26 disclosures: Defendant knows that is an "individual likely to have discoverable information." Fed. R. Civ. P. 26(a)(A)(i). As will testify, Defendant was on the island with her and interacted with her on a regular basis. Defendant's refusal to disclose her is not only (yet another) discovery violation, but also a part of the secrecy that Defendant and Epstein strove to maintain surrounding their sex trafficking ring. Defendant should not be allowed to participate in a sex trafficking rin conceal the witnesses (and victims) of that ring, and then proclaim "surprise" when Ms. succeeds in locating one of the victims. Simply put, she should not be allowed to benefit from her obvious failure to properly disclose= Testimony is Not Cumulative And Has Highly Relevant Evidence Defendant also advances the remarkable argument that it is "unlikely" that Ms. will have relevant information. Yet witnessed — first hand — Defendant's involvement in sex trafficking with Jeffrey Epstein. Nor will her testimony be cumulative. First, at the heart of this case is Defendant's sworn testimony that she was not involved in sex trafficking with Epstein. an directly refute Defendant's sworn testimony under oath in numerous ways. ...theprimary pu se of those visits was to have me have sexual relations with Jeffrey, and various other girls and guests brought to the island...During one of my first visits to the island I met Ghislaine Maxwell. Watching her interact with the other girls on the island, it became clear to me that she recruited all or many of them to the island. Once they were there, she appeared to be in charge of their activities, including what they did, who they did it with, and how they were supposed to stay in line. She assumed the same supervisory role with me as soon as I arrived. Some of the girls appeared to be 18 or older but many appeared to be young teenagers. Exhibit A, Affidavit of . In addition, Defendant has made known her plan to put forth Alan Dershowitz as a witness at trial to testify that Ms. is lykgisnd that he never had sex with her or anyone else provided by Jeffrey Epstein. While Ms. contends that Dershowitz's testimortot relevant to this case concerning Defendant, in the event that the Court disagrees, Ms. directly contradicts this testimony because, as part of her EFTA00590750 SOIES. SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -3- Confidential Sealed Filing involvement in the sex trafficking ring, like Ms. =, Ms. was also required to engage in sexual acts with Jeffrey Epstein and Alan Dershowitz. In addition to spending time with Jeffrey on his island, I spent time with him in New York City... Among the people he lent me to was his friend Alan Dershowitz. On one occasion I was in a bedroom at Jeffrey's New York townhouse with Jeffrey and After a short time, Alan Dershowitz entered the room after which Jeffrey left the room and and I had sex with Dershowitz... See Exhibit A. Affidavit of The testimony of Ms. goes to the heart of this defamation claim— whether or not Ms. was truthful in her claims about Defendant's involvement in Epstein's sex trafficking ring, and the Court should allow the jury to hear her. aMs. Has Diligently Participated In Discovery And Promptly Disclosed Ms. After Conducting Due Diligence Defendant also insinuates that Ms. has delayed in disclosing Ms. But as the Court is well aware, Ms. has previously diligently disclosed close to 100 individuals who may have relevant information in her Rule 26 disclosures. By contrast, Defendant's Rule 26 disclosures never listed Ms. as a witness, despite the fact that Defendant was in her company on several occasions including on Epstein's island, where Ms. was one of several girls being sexually trafficked for Epstein upon the direction and insistence of Defendant. After being contacted by Ms. , counsel for Ms. properly conducted a dueSesce investigation into whether the information she provided had merit. Specifically, Ms. counsel undertook the expense to fly to Europe to meet in person with this newly disclosed witness on January 4, 2017, returning on January 6, 2017, to fully evaluate her credibility. Upon evaluating the witness and upon the witness confirming that she was willing to sign an affidavit under oath regarding her testimony, Ms. arranged to have a sworn affidavit executed at the U.S. Embassy in the country where Ms. resides. Ms. then issued revised Rule 26 disclosures on January 13, 2017 and informed Defendant that she would produce Ms. for a deposition as a newly-disclosed witness immediately so as to avoid any prejudice or delay in the March 13, 2017 trial date. In short, Ms. acted promptly and reasonably after being contacted by this victim of Epstein's and Defendant's sex trafficking ring. Defendant Will Not Be Prejudiced Because Ms. is Readily Available for Deposition EFTA00590751 BOIES, SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -4- Confidential Sealed Filing Defendant's argument about her alleged burden from allowing this one additional witness also rings hollow.' Defendant complains about her alleged lack of resources, but as this Court is aware, Defendant is a wealthy socialite (who recently sold her New York Townhome for S15 million dollars) who has heavily litigated this case in ways that were completely unnecessary. 2 Moreover, deposition discovery is still ongoing in this case. Ms. sat for her deposition last week (wherein she invoked the Fifth Amendment when asked about Defendant's involvement in Epstein's sex trafficking ring) along with Ms. who was recently deposed on January 17, 2017. Due to Defendant's unwillingness to produce her agent, Ross Gow for deposition, Ms. did not get to depose him until November 18, 2017 at which time he produced never-before-seen documents that are critical to this case. Defendant has yet to sit for her follow-up deposition that was directed by the Court but for which Defendant filed a "Motion for Reconsideration" on November 16, 2016, which is still pending. Needless to say, while the official discovery deadline has closed, certain depositions have been taken more recent) due to issues with witness cosation. Of course, if Defendant does not desire to take Ms. deposition, then Ms. is content simply calling her at trial. But Defendant will hardly be prejudiced by allowing a witness to testify who is available for deposition. 'Defendant ar ues that because Jane Doe 43 (who for purposes of this sealed filing we can identify as Ms. has recently filed a complaint against multiple defendants for violations of sex trafficking laws that Defendant should get to reopen discovery and further investigate everyone named as a Defendant. Notably, these are all individuals that were part of the sexual trafficking ring that Defendant was a party to and she has known about them and interacted with them for years. Ms. claim had to be filed swiftly because her statute of limitations was continuing to run and the details of her allegations only recent' ccame known to counsel. In any event, the questions that need to be asked of Ms. are simply and straightforward: Was Defendant involved in Epstein's sex trafficking ring? That question has been at the heart of this case for many months and exploring it does not raise any new issues. 2 For example, Defendant litigated over the production of facially non-privileged documents; Defendant filed no fewer than three frivolous sanctions motions; Defendant filed Dauber! challenges to all six of Ms. expert witnesses; and Defendant has filed discomotions without even conferring with Ms. in advance, includin one for which Ms. did not oppose the relief sought (Defendant's motion to reopen Ms. deposition). Further, Defendant aently had the resources to file approximately 100 pages of single-spaced objections to Ms. deposition designations, an unorthodox volume that stands out not simply because this is a one-count defamation claim, but because she objects to the same type of testimony that she has designated for admission. EFTA00590752 BOIES. SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -5- Confidential SealedFiling The Case Law Supports Allowing Ms. As A Trial Witness Ms. has offered Defendant, subject to this Court's approval, the opportunity to take Ms. deposition. And, as this Court has already explained, taking the deposition of a newly-discovered witness cures any prejudice: "[t]his and other courts have adopted the taking of depositions as an appropriate mechanism to address late-disclosed witnesses." MB/A Ins. Corp. v. Patriarch Partners VIII, LLC, 201 WL 2568972, at *14-15 (S.D.N.Y. Sept. 29, 2003) (concluding that plaintiff should be given the opportunity to depose a late-identified witness). The cases that Defendant cites are all vastly different from the case before this Court and are easily distinguishable. In Gray v. Town ofDarien, 927 F.2d 69 (2d Cir.1991), the court denied the motion to reopen discovery and granted summary judgment because the plaintiff failed to seek any discovery during the six-month discovery period set forth by the court. In stark contrast, Ms. has actively engaged in discovery. The fact that this witness had critical information as a victim of Epstein and Defendant's sex trafficking ring could not have been known by Ms. until the witness contacted Ms. lawyers. In Trebor Sportswear Co., Inc. v. The Limited Stores, Inc., 865 F.2d 506 (2d Cir. 1989), a case involving a statute of frauds issue, the court would not let the parties re-open discovery because there was no reason to believe that they would find a missing written agreement. Here, Ms. has found a witness who has will provide to the jury critical information about Defendant's involvement in sex trafficking that directly contradicts Defendant's sworn testimony. In Smith v. UnitedStates, 834 F.2d 166 (10th Cir. 1987), the plaintiff made his request for a new witness on the morning of trial, having had eight months to conduct depositions. Additionally, the Tenth Circuit found that the new witness would not even be relevant to the narrow issue being addressed at trial. Id. at 169. In contrast, Ms. has provided Defendant ample time to conduct discovery on Ms. I , a witness who has vital evidence on the central issues in this case. In Vineberg v. Bissonnette, 548 F.3d 50, 55 (1st Cir. 2008), the First Circuit found that the defendant failed to point to any "relevant leads" that she mi t have obtained had the court reopened discovery. Here, it is patently obvious that Ms. holds a wealth of valuable information and is, as Defendant herself admits, a significant witness. Finally, in .leannite v. City ofN.Y. Dept, of Buildings, 2010 WL 2542050, at 4'2 (S.D.N.Y. June 21, 2010), plaintiff waited until the very end of discovery to make the request and had not sent any document requests or sought to depose any which is in contrast to Ms. having aving actively partici ated in . Furthermore, there was no way for Ms.h to know that Ms. had such critical information until she called us because Defendant never disclosedher. Accordingly, Defendant fails to accurately support her claims with any relevant case law. Conclusion EFTA00590753 SOIES, SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -6- Confidential SealedFiling For the foregoing reasons, this Court should allow Ms. to include Ms. as a witness to be called at the trial scheduled to begin on March 13, 2017. Again, Ms. commits to making Ms. available for deposition at the reasonable convenience of Defendant's counsel. Respectfully submitted, McCawlev Sigrid McCawley SM/ cc: Counsel of Record EFTA00590754 EXHIBIT A CONFIDENTIAL EFTA00590755 CONMEMAL United States District Court Southern District of New York Plaintiff Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. AFFIDAVIT swear and affirm as follows: 1. I am currently over the age of 18 and presently reside in the country of Spain. 2. In the summer of 2006, when I was twenty-two years old and livin in New York, I was introduced to Jeffrey Epstein by a girl I had met named Malyshov. Shortly after meeting Jeffrey he invited me to fly to s private island in the US Virgin Islands, which I did. After that first trip I traveled to the island several more times, usually on one of Jeffrey's private airplanes, and always at his direction. I am told that my name appears on the flight logs of one or more of those trips. On a few occasions, Jeffrey also arranged to have me flown to the island on commercial flights. As it turned out, the Mary purpose of those visits was to have me have sexual relations with Jeffrey, Macinkova, and various other girls and guests he brought to the island. 3. During one of my visits to the island I met Ghislaine Maxwell. Watching her interact with the other girls on the island, it became clear to me that she recruited all or many of them to the island. Once they were there, she appeared to be in charge of their activities, including what they did, who they did it with, and how they were supposed to stay in line. She assumed the same supervisory role with me as soon as I arrived. Some of the girls appeared to be 18 or older, but many appeared to be young teenagers. I recall seeing a particularly young, thin girl who looked well under 18 and recall asking her her age. I later learned was a ballerina. She refused to tell me or let me see her passport. 4. In addition to spending time with Jeffrey on his island, I spent time with him in New York City. At his town house I was also lent out by him to his friends and EFTA00590756 COIF ENT'OAL associates to have sex. Among the people he lent me to was his friend, Alan Dershowitz. On one occasion I was in a bedroom at Jeffrey's New York townhouse with Jeffrey and After a short time, Alan Dershowitz entered the room, er e y left the room and and I had sex with Dershowitz. I recall specific, key details of his person na sex acts and can describe them in the event it becomes necessary to do so. I affirm under penalty of perjury that the foregoing is true and correct. Dated: 1 -07A9as EFTA00590757 cesar—Laa.v.--r • CONFIDENTIAL CERTIFICATE OF ACKNOWLEDGMENT OF EXECUTION OF AN INSTRUMENT The Kingdom of Spain (Count') Province of Barcelona rcountrone/or Other Peatical Division) SS: City of Barcelona (County end& Other Political Division) Consulate Gral.of the United States of America (Name of Foreign Service Offne) Ilsiao-Ching Chang,Vice Consul of Me United stares of America at Barcelona, Spain duly commissioned and qualified, do tienty certify that on this day of 01-05-2017 . before me personalty appeared Dale grim-dd-yyyy) Emma Ashley te ..h. .... • . I known to me to be the individual-describedin, whose name iS subscribed to, and amo executed the annexedInstrument and being informed by me of the contents of said instrument she duly acknowfedged to me Mal she executed the same freely end voluntarily for the uses andpurposes therein mentioned. (SEAL; vobvSS whereof l have hereunto set my hand and official seal the day and yearns! above written. I lsiao-Ching Chang Vice Consul of the owed stales °mamma This document consists of 4 pages. including the Acknowledgement certificate. NOTE: Wherever practicable all signatures to a document should be included in one certificate. OF-17S rFormeily FS-88) 01.2009 EFTA00590758

EFTA00808026.pdf

DataSet-9 Unknown 28 pages

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") and states as follows:' SUMMARY OF ARGUMENT Edwards' Renewed Motion for Summary Judgment should be denied for numerous reasons. First, Epstein has not had an opportunity to conduct discovery essential to refute Edwards' arguments. Edwards' insufficient privilege log has tied relevant discovery in knots. Second, Edwards filed a "Statement of Undisputed Facts" with exhibits — all of which violate Rule 1.510 and should be stricken. The "undisputed facts" are impertinent and entirely irrelevant, as are the unswom and unauthenticated exhibits on which Edwards improperly relies Nothing factually new has been submitted by Edwards. The Statement of Undisputed Facts is identical to the one used for Edwards' first Motion for Summary Judgment. EFTA00808026 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ to obtain summary judgment. Third, Edwards has not demonstrated the absence of material issues of fact. His alleged participation in and/or knowledge of the Rothstein Ponzi scheme and the validity of, and motivation in conducting, the discovery at issue in the underlying Epstein actions are matters of considerable debate. Finally, as a matter of law, Edwards cannot secure summary judgment on the basis of the sword and shield doctrine or the litigation privilege. STATEMENT OF THE CASE A. Delay in Discovery Pending Resolution of Pleadings On December 7, 2009, Jeffrey Epstein filed his Complaint against Bradley J. Edwards and Scott Rothstein, seeking damages based on a scheme involving the marketing of investments in lawsuits brought against the Plaintiff. Edwards filed his Answer and Counterclaim for Abuse of Process on December 21, 2009. On or about August 24, 2011, Epstein filed a narrowly-drawn Corrected Second Amended Complaint, consisting of a single count against Edwards for abuse of process, and a single count against Rothstein for conspiracy to commit abuse of process. Epstein alleged that Edwards committed abuse of process by filing the Federal ■. action, deposing Epstein's airline pilots and brother without asking any questions regarding the claims of Edwards' clients, noticing for deposition famous acquaintances of Epstein who had no knowledge of the claims, issuing a subpoena to a doctor who never treated Epstein, seeking health-related documents when Epstein's health was not at issue, and filing an unfounded motion to freeze Epstein's assets. From April 11, 2011 to November 17, 2011, the Court had stayed discovery until the Plaintiff had a Complaint which survived a Motion to Dismiss. 2 EFTA00808027 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ B. RR:', Bankruptcy - Efforts to Get Records On May 18, 2010, Judge Raymond Ray, Bankruptcy Judge for the United States Bankruptcy Court for the Southern District of Florida ("Bankruptcy Court") entered an order that established the process for anyone wishing to obtain discovery from the Trustee. The operation of the Order was not limited to parties in the bankruptcy case. Further, the Bankruptcy Court determined it had jurisdiction and retained jurisdiction with respect to all matters arising from or related to the implementation or the interpretation of its Order without any limitation on the form (A:1). On July 14, 2010, Plaintiff filed a Motion to Compel Production of Documents from the Trustee pursuant to the document production protocol established by the aforesaid Order (A: 2). On August 4, 2010, the Bankruptcy Court conducted a hearing on Plaintiffs Motion to Compel and entered an Order on August 13, 2010 appointing former Broward County Circuit Court Judge Robert Carney as Special Master to review the documents responsive to the Plaintiff's subpoena served on the Trustee, to determine the applicability of any privileges asserted by ■., Bradley Edwards, or other former clients of Farmer Jaffee, where Edwards presently works, and to prepare a privilege log. The Plaintiff, without objection, agreed and was ordered to pay the legal fees and costs incurred by the Special Master in the preparation of this log (A :5). Prior to the hearing, two motions in opposition were filed by Farmer Jaffee (A: 3 and 4). Subsequently, on October 13, 2010, the Special Master filed a motion seeking clarification of the Order appointing him (A: 7). Farmer Jaffee filed another motion in 3 EFTA00808028 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ opposition (A: 8 and 9). A hearing took place and an Amended Order was entered, which allowed Farmer Jaffee to review and assist in the preparation of the privilege log (A: 10). Farmer Jaffe received a portion of the electronically stored data on October 17, 2010 and was required to prepare a detailed privilege log within thirty (30) days of receipt of the compact disk, i.e., on or before November 15, 2010, at its cost (A: 10). On November 2, 2010, ■. and Bradley Edwards filed a Motion for Relief from the Amended Order and sought to have the Plaintiff pay for the production of all documents and fees associated with the privilege log, which previously had been ordered by the Court for Farmer Jaffe to pay. In addition, Farmer Jaffe and Edwards asked for more time (A: 12). As a result of the Motion, an Agreed Order was entered granting additional time, and the Plaintiff agreed to pay the cost of making physical copies of the documents on the compact disks for the purpose of making it more convenient for Fanner Jaffee to prepare the privilege log (A: 13). Even though Farmer Jaffee had received one compact disk on October 19, 2010 and received another compact disk on or about November 15, 2010 from the Trustee, on December 16, 2010, Fanner Jaffee filed an emergency motion, after agreeing to the Order granting additional time, not only for an extension of time but also for a stay in the preparation of the privilege log pending its Motion for Summary Judgment to be heard by this Court (A: 16). Edwards filed a similar motion with this Court which is presently set for hearing on January 27, 2011. On December 21, 2010, the Bankruptcy Court conducted a hearing and entered an Order allowing through January 31, 2011 for the privilege log to be prepared (A: 17). 4 EFTA00808029 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ [ADD PRIVILEGE HISTORY - PENDING MOTION.] C. Present Renewed Motion for Summary Judgment On November 4, 2011, Edwards filed a Renewed Motion for Final Summary Judgment on the ground that Epstein could not seek affirmative relief because he had invoked the Fifth Amendment at his deposition; Edwards' conduct was protected by a "litigation privilege;" and Edwards was not involved in the Ponzi scheme (D.E. 390). On or about November 7, 2011, Edwards filed a "Statement of Undisputed Facts" dated November 2, 2010 (D.E. 393), which is exactly the same "Statement of Undisputed Facts" that he filed in September 2010 for his initial Motion for Summary Judgment. Nothing has changed in this recitation of "Facts," even though depositions of investors have occurred which present disputed facts under oath based on personal knowledge, which is just about all that Edwards presents here. ARGUMENT LEGAL FRAMEWORK FOR SUMMARY JUDGMENT MOTIONS In order to obtain summary judgment against Epstein, Edwards must show: (1) the nonexistence of a material factual issue, and (2) entitlement to judgment as a matter of law. Fla. R. Civ. P. 1.510(c), (2006). In Florida, the party moving for summary judgment must conclusively demonstrate the nonexistence of an issue of material fact, and the court must draw every possible inference in favor of the party against whom summary judgment is sought. Summary judgments should be cautiously granted, and the trial court should not enter summary judgment unless the facts are so crystallized that nothing remains but questions of law. If the 5 EFTA00808030 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ evidence will permit different reasonable inferences, it should be submitted to the jury as a question of fact, and summary judgment should not be granted. McCraney v. Barberi, 677 So. 2d 355, 357 (Ha. 1s' DCA 1996); Albelo v. Southern Bell, 682 So.2d 1126, 1129 (Ha. 4'h DCA 1996). Finally, summary judgments are not favored. O'Connor v. Marston, 717 So. 2d 82 (Ha. 5th DCA, 1998). It is also necessary for the movant to authenticate the undisputed facts upon which its claim for summary judgment is based. Most of the facts and assertions contained throughout Edwards' motion are unauthenticated and cannot form the basis for any summary judgment. Ha. R. Civ. P. 1.540; Bifidco v. State Farm Mutual Automobile Insurance Co., 693 So.2d 707 (Fla. 4th DCA 1997). Pursuant to Fla. R. Civ. P. I.510(c), a motion for summary judgment must specifically identify "materials as would be admissible in evidence...on which the movant relies." Statements in an affidavit that are irrelevant to the claims in suit cannot be considered on a motion for summary judgment. See, e.g., Food Fair Stores, Inc. v. Dwell, 131 So 2d 730 (Fla. 1961). An affidavit based on hearsay does not provide a basis for summary judgment. See, e.g., Castro v. Brazeau, 873 So. 2d 516 (Fla. 4th DCA 2004). By the same token, conclusory allegations in an affidavit do not raise issues of facts and should be stricken. See, e.g., Reinke v. O'Connell, 790 F. 2d 850, 851-52 (11th Cir. 1986). Finally, summary judgment should not be granted until all discovery has been completed. See, e.g., Sica v. Sam Caliendo Design, Inc., 623 So.2d 859 (Fla. 4th DCA 1993). 6 EFTA00808031 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ SUMMARY JUDGMENT MAY NOT BE GRANTED FOR EDWARDS BECAUSE CRITICAL DISCOVERY HAS BEEN STALLED 1. Documents. Plaintiff has been attempting since last spring to obtain discovery of communications, primarily in the form of emails originated and received at RRA with the intent to depose appropriate witnesses after having had an opportunity to review the content of the documents. To this end, Plaintiff served a subpoena on the bankruptcy Trustee appointed to stand in the place of the now-defunct firm's management since before this case was filed. The subpoena resulted in proceedings before Honorable Judge Ray of the U.S. Bankruptcy Court, who appointed a Special Master. In response to several Orders entered by Judge Ray, Edwards filed a I59-page privilege log claiming that over 200 documents were privileged. Epstein has moved to compel production of documents by Edwards on the ground that the privilege log was woefully insufficient. A hearing on Epstein's Motion to Compel Production of Documents by Defendant Bradley Edwards and for Sanctions is pending. 2. Rothstein Deposition. For the first time, on July 1, 2011, the District Court authorized Rothstein's deposition to begin on December 12, 2011, granting a stay to the government. Epstein sought leave of the Bankruptcy Court to take the deposition of Scott Rothstein on December 1, 2011. At that time, Judge Ray denied the Motion without prejudice, because there was no time in the schedule to depose Mr. Rothstein. The deposition of Scott Rothstein was taken in the bankruptcy proceeding of Rothstein, Rosenfeldt and Adler ("RRA"), but not completed, from December 12, 2011 through December 7 EFTA00808032 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ 22, 2011, by Order of Judge Cohn, the Federal judge presiding over Rothstein's criminal case. Only a limited number of parties had an opportunity to question Rothstein during that time. On January I I, 2012, Epstein filed a Renewed Motion to Depose Scott Rothstein. On February 1, 2012, Epstein's Renewed Motion was heard by Judge Ray, who denied it without prejudice to seek leave from Judge Cohn to be allowed to participate in the second deposition. Epstein then filed a Motion for a Writ of Habeas Corpus Ad Testificandum to Depose Scott Rothstein, which Motion was granted by Judge Cohn on February 13, 2012. Judge Cohn ordered that the second deposition take place from June 4, 2012 through June 15, 2012. Up until now, Epstein has not had an opportunity to depose Rothstein; and as the record demonstrates, he has proceeded with all due diligence to take Rothstein's deposition. Rothstein's testimony is critical in the instant case. He is the central figure with personal knowledge of material facts relating to Epstein's claims against Rothstein and Edwards. Some of the relevant documents that Epstein has obtained show, among other things, that Rothstein was involved in supervising and/or managing the Epstein cases; the Rothstein firm developed a strategy to go after those persons closest to Epstein; RRA files of the Epstein cases were shown by Rothstein to the Razorback investors; the purpose of the Ponzi scheme was to personally enrich Rothstein and other co-conspirators and to supplement the income and sustain the daily operation of RRA; to achieve this purpose Rothstein and other co-conspirators utilized the offices of RRA and the offices of other co-conspirators to convince potential investors of the legitimacy and success of the law firm, which enhanced the credibility of the purported investment opportunity; RRA relied upon the Ponzi scheme to supplement and support the 8 EFTA00808033 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salaries and bonuses, and to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of the persons employed by and associated with RRA. Thus, Rothstein's testimony is critical to the issues raised in Edwards' summary judgment motion. It is essential that Epstein be able to ask Rothstein to be able to authenticate documents he authored and to question him about his actions in marketing the Epstein litigation to the Razorback investors. Rule 1.510(f) provides that a court may refuse the application for summary judgment or order a continuance for depositions or discovery to be taken. Pursuant to Rule 1.510(f), summary judgment is premature because extensive discovery is pending. See, e.g., Sica, 623 So. 2d at 860 (reversing grant of summary judgment where properly-noticed deposition had not as yet been taken); Singer v. Star, 510 So. 2d 637, 639 (Fla. 4th DCA 1987) ("Facts upon which the court based its decision were not fully developed because discovery was in progress, and depositions were pending. Summary judgment was therefore premature."). Epstein submits that this case is not the normal run-of-the-mill, slip and fall tort case or breach of contract case. A former law firm with 77 lawyers collapses when its leader perpetrates a giant, gigantic fraud brought about by use of the law firm. The principal member and person most knowledgeable of the events has pled guilty and has been sentenced to 50 years in prison. If one were to go on the United States Bureau of Prisons' website, he or she would not find Scott Rothstein listed as a prisoner incarcerated there. He remains under high security protection. Various efforts to depose him have only recently been successful, with Judge 9 EFTA00808034 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ Cohn's ruling, giving the United States government up until December 1, 2011 to complete its investigation for any other indictments arising out of this law firm fraud. The law firm itself is in Chapter 11 Bankruptcy. The Trustee has commenced approximately 127 adversary proceedings in order to reclaim law firm funds dissipated for the purpose of this Ponzi scheme. It is not a simple process of subpoenaing the documents that related to this firm. First, they are under the control of the U.S. Bankruptcy Court, not this Court. Second, and more importantly, all of the documents were created by a law firm and are subject to numerous privilege challenges. Even the government has had ( order ) two teams of lawyers reviewing in excess of six figures of documents for privilege issues for their indictment. Certainly that takes precedence over a civil action. And, as Judge Cohn noted, Epstein was lucky to be able to depose Rothstein. Under normal circumstances ( insert cite ), a writ of habeas corpus from a State Court to the Bureau of Prisons is unenforceable and is subject completely to the discretion of the Bureau of Prison Officials ( CVR cite ). It is simply not realistic, believable, or fair to allow Mr. Edwards to oppose every effort by Epstein to get documents or to prepare the case, while t the same time seeking to fast track two — not one — but two summary judgment motions on a matter that is clearly not concluded or ready or ripe for summary judgment hearing. As previously argued, Epstein respectfully renews its Motion to either deny Edwards' Motion as not ripe or postpone it until further discovery has been able to take place. I0 EFTA00808035 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ EDWARDS' SUMMARY JUDGMENT MOTION MUST BE DENIED BECAUSE HIS "STATEMENT OF UNDISPUTED FACTS" IS SCURRILOUS AND IRRELEVANT On November 3, 2011, Edwards served a Renewed Motion for Summary Judgment together with a thirty-seven (37) page "Statement of Undisputed Facts," consisting of 120 separate paragraphs, most of which are either not material at all or, where arguably material, are nonetheless disputed. At best only paragraphs 86 through 91 bear on the subject of this lawsuit.'- 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." 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 unswoni 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 2 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 alleged conduct not in issue in this case, such as Plaintiffs alleged sexual exploits with clients of Edwards. There can be no other reason, since the Plaintiff has not placed those matters in issue. Edwards persists in attempting to use sex to shift the focus from his own conduct. 3 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 at RRA 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 II EFTA00808036 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ 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 Sheriffs Office, flight logs, and other documents the materiality of which is not facially apparent.' Edwards' Statement of Material Facts is a nasty mass of entirely irrelevant statements based on hearsay and otherwise inadmissible materials that do not conform to the Rules of Civil Procedure. It is a bad faith, if not reprehensible, attempt to smear and embarrass Epstein and others under the guise of compliance with Rule 1.150(c). Although Edwards relies on the following portion of Rule 1.510(c) to justify his submission, such reliance is misplaced because Edwards is the movant, not the adverse party: " The adverse party shall . . . identify any summary judgment evidence on which the adverse party relies . . ." No portion of Rule 1.150 authorizes the filing of hundreds of immaterial and impertinent "facts" in support of summary judgment, particularly where the motion itself does not depend upon proof of such "facts." victim of Rothstein (Exhibit "TT"), but has not yet been provided the documentary evidence he has been seeking to use against Edwards. 4 For example, Attachment "I" purports to be a 183-page deposition of Plaintiff in a case styled M. 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. 12 EFTA00808037 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ Edwards' "facts" fall into the following categories which, on their face, are unrelated to Epstein's abuse of process claim and Edwards' defenses: "sexual abuse of children by Epstein" (911 1-18); Epstein's plea agreement with the Federal government (1119-30); Edwards' agreement to represent ■., M., and Jane Doe and the Crime Victim Rights Act filed by ■. and.. (911 31-40); Epstein's entry of guilty pleas to sex offenses (11 41-44); lawsuits filed by other attorneys against Epstein and settlements in those cases (191 48-52); invocation of the Fifth Amendment by Epstein and alleged co-conspirators in depositions taken in the "Epstein Actions" M., ■., and Jane Doe) and other similar lawsuits (111 54-58); "blocking" of discovery by various witnesses (9191 59-66); Epstein's purported association with Jean Luc Brunel, who allegedly ran a modeling agency and sexually assaulted underage models who "presumably live(d) as underage prostitutes in condos owned by Epstein" (191 65; see also 62-67); Edwards' rationalization as to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico claims and punitive damages (911 77-79); Epstein's interview with a New York newspaper reporter (9191 80-81); Epstein's alleged threats to witnesses (11 82-83); settlements in the Epstein Actions 84-5); and Edwards' purported non-involvement in the Ponzi scheme (1186-91). This Court has ruled that Edwards is not entitled to discovery regarding Epstein's alleged sexual misconduct because it is irrelevant. (See ). What allegedly transpired between Edwards, M., and others simply does not disprove the allegations of abuse of process or Edwards' defenses. Nevertheless, Edwards has made sexual misconduct the 13 EFTA00808038 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ centerpiece of his Statement of Undisputed Facts, filling the first 10 pages with graphic and irrelevant details. It is readily apparent that Edwards' sole purpose in placing such scurrilous "facts" and materials into the court file and the public domain is to vilify Epstein. There can be no other reason for Edwards' baseless filing. Moreover, the vast majority of the remaining "facts" are not remotely relevant to the allegations that Edwards engaged in abuse of process by filing the Federal M. action, deposing Epstein's airline pilots and brother without asking questions regarding the claims of Edwards' clients, noticing prominent acquaintances of Epstein who had no knowledge of the claims, issuing a subpoena to a doctor who never treated Epstein, seeking health-related documents when Epstein's health was not at issue, and filing an unfounded motion to freeze Epstein's assets. Nor are any of the remaining "facts" even remotely relevant to Edwards' summary judgment arguments based upon the litigation privilege, the sword and shield doctrine, and the Ponzi scheme. The following examples will vividly illustrate this point. Irrelevant to the point of absurdity are extensive "facts" regarding the alleged sexual misconduct of purported acquaintance Jean Luc Brunel and his visits to Epstein in jail (see 11 62-67); invocation of the Fifth Amendment by alleged "co-conspirators" none of whom are named in the operative Complaint or Edwards' summary judgment motion (see 11 54-58); alleged fabrication by third parties (see 11 61-2); and Jane Doe's "escape() to Australia (see 151). None of these "facts" is remotely relevant to the abuse of process allegations and Edwards' defenses. These are just a few of the more egregious examples of immaterial "Facts" that vividly illustrate why the Edwards' Statement of Undisputed Facts should be stricken. 14 EFTA00808039 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ Further undermining the validity of Edwards' Statement of Undisputed Facts is the fact that Edwards only cites his Statement sporadically and generally in his summary judgment motion (see pp. 9, 10 at n. 2, 13, 14 and 15), and does not reference any specific "facts" in his summary judgment motion. The only conclusion to be drawn is that Edwards' "Statement of Undisputed Facts" is a sham and should be stricken. EDWARDS' "SUPPORTING PAPERS" VIOLATE FLA. R. CIV. P. 1.510 AND SHOULD BE STRICKEN, AS SHOULD ALL "FACTS" BASED THEREON Edwards' "Supporting Papers" — with the exception of Exhibit N, Edwards' Affidavit — violate Rule 1.510 because they are not properly authenticated and are based on inadmissible hearsay. They must be stricken together with the "facts" based thereon. a. No Authentication. None of the Supporting Papers, save two, is sworn or certified in any manner whatsoever. None of the Supporting Papers is accompanied by an affidavit of a records custodian or other individual attesting to its authenticity, completeness or correctness. For example, Attachment "I" 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 a 9-page unauthenticated excerpt to support the statement that Jane Doe was abused at least 17 times, but the excerpt does not support that statement. Attachments "3" through "22" suffer from the same defect. The exhibits are no better. 15 EFTA00808040 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ The law is settled that unauthenticated documentary evidence may not be relied on or considered in support of a motion for summary judgment. See, e.g., Hollywood Towers Condominium Ass'n, 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); Eifitico, 693 So. 2d at 710 (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. 4th DCA 1989) (contractual exhibits which were unaccompanied by an affidavit could not be considered in support of motion for summary judgment). In &fitico the court observed, 693 So. 2d at 710 (emphasis added) : [lit is unquestionably clear that the documents attached to Edwards' 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 Appellees counsel. In short, rule 1.510(e), by its very language, excludes any document from the record on a motion for summary judgment 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 justify the granting of summary judgment in its favor. b. Inadmissible Hearsay. In addition, the Supporting Papers and "facts" based thereon must be stricken because they contain inadmissible hearsay. First, the Supporting Papers were not authenticated by anyone in an attempt to lay the required foundation for admissibility as public or business records. See Gray v. State, 910 So. 2d 867, 869 (Fla. 1st DCA 2005) 16 EFTA00808041 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ (document on Department of Corrections letterhead was hearsay where foundation not laid for its admission as a business record or a public record); Bifidco, 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); Adams v. State, 521 So. 2d 337, 338 (Fla. 4th DCA 1988) (business records are inadmissible without a proper foundation for their admission). See also Fridman v, City of N.Y., 183 F. Supp. 2d 642, 646 n.2 (S.D.N.Y. 2002) (newspaper articles disregarded as hearsay). The following documents included in the Supporting Papers are being offered by Edwards to prove the truth of the matters asserted therein and are rank, prejudicial hearsay: the "Holy Grail" (Ex. F), a "journal" assertedly taken from Epstein's computer and cited by Edwards inn 16-18; correspondence between the U.S. Attorney and Jay Leflcowitz, Esq. (Exs. C and D and 9fq 6, 20, 25) and Lilly Ann Sanchez, Esq. (Ex. L andl 28); a book receipt (Ex. I and 1 22), message pads (Ex. A. 1 24) and a property receipt (Ex. O and 1 34) ; correspondence between the FBI and and (Ex. M and 11 29, 30); newspaper articles and photos and blogs (Exs. X, Y, AA, DD, FF, LL, NN,9191 50, 52, 59, 61, 62, 68, 71); a jail visitor log (Ex. GG, 1 63); and flight logs (Ex. MM, 1 72). Accordingly, the Supporting Papers must be stricken, as should the "facts" based thereon. Third, the Palm Beach Police Incident Report (Ex. A), cited widely by Edwards in support of 113, 12, 13, 21, 23, 27, 82, constitutes double hearsay, and cannot be used to support his summary judgment motion. See Burgess v. State, 831 So. 2d 137, 140 (Fla. 2002) ("The information contained in police reports is ordinarily considered hearsay and inadmissible in an 17 EFTA00808042 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ adversary criminal proceeding."); Jenkins v. State, 803 So. 2d 783, 2001 Fla. App. LEXIS 16957 (Fla. 5th DCA 2001) ("Where basis for involuntary commitment came from admission of police reports with unswom allegations of serious sexual misconduct, evidence was hearsay, and perhaps multiple hearsay, and thus could not be the basis for commitment; trial court erred in admitting the same as it amounted to violation of patient's right to confrontation."); Kashino v. Morel!, 449 So. 2d 958, 959 (Fla. 4th DCA 1984) (police accident report inadmissible in civil suit). Thus, Edwards' reliance on the Palm Beach Police Incident Report is egregious error. The report and "facts" based thereon must be stricken. Finally, inadmissible and improper triple hearsay forms the basis of the "facts" set forth in ¶ 80, in which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Rush. EDWARDS' "FACTS" PERTAINING TO OTHER PURPORTED ACTS OR WRONGS ARE NOT PROBATIVE AND ARE HIGHLY PREJUDICIAL Many, if not the majority, of Edwards' "facts" detail in graphic terms alleged misconduct by Epstein wholly unrelated to the allegations in the instant litigation. Pursuant to Fla. R. Evid. §90.404(1), evidence of other crimes, wrongs or acts is inadmissible when the evidence is introduced solely to prove bad character, or that the person acted in conformity with his character. See, e.g., Jacobs v. Westgate, 766 So. 2d 1175 (Fla. 3d DCA 2000) (error to admit evidence that roommate bounced checks in action for negligent disposition of property because such evidence was inadmissible to "disparage" plaintiffs character). Thus, Edwards' evidence 18 EFTA00808043 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ of other wrongs has been put into a public document solely to smear Epstein and poison the well. However, §90.404(I), Fla. Stat., prohibits the admission of other wrongs evidence for purposes of character assassination. ALLEGATIONS DO NOT CONSTITUTE UNDISPUTED FACTS To the extent that Edwards' "facts" are based on allegations in various complaints, they are improper and should be stricken. (See 11 4, 71, Ex. B). For example, Edwards cites the Jane Doe 102 Complaint in support of the "facts" in 1 4 that "there is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds." Edwards' reliance on such allegations to proof of undisputed "facts" is egregious. It is well settled that mere allegations do not constitute "facts" for purposes of summary judgment. See, e.g., Metro. Dade County v. Wilkey, 414 So. 2d 269, 271 (FIa. 3d DCA. 1982) ("[P]leadings are not admissible in evidence to prove or disprove a fact in issue.") (citing Hines v. Trager Construction Co., 188 So.2d 826 (Fla. 1st DCA 1966) (the pleadings of a cause are merely tentative outlines of the position the pleader takes before the case is fully developed on the facts, and hence are inadmissible to prove facts alleged therein)). PLEA NEGOTIATIONS AND RELATED PAPERS ARE INADMISSIBLE Edwards' "facts" and Supporting Papers regarding plea negotiations and a plea agreement between Epstein and the U.S. Attorney's Office, including letters between the U.S. Attorney's Office and Epstein's counsel, a prosecution memo and indictment, an investigation by the Palm Beach Police Department, and notification of .. and.. (see 11 5, 20-30; Exs. A, C, H, I, K, 19 EFTA00808044 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ L, M) must be stricken for numerous reasons. First, none of the purported "facts" detailed in 5, 20-30 are even remotely relevant to the issues in suit. It is readily apparent that Edwards' assertions that Epstein was successful in "attempt[ing] to avoid the filing of numerous federal felony offenses" (1 5) and "Epstein's attorneys knew of Epstein's scheme to recruit minors for sex..." (¶ 6) are extraneous and highly prejudicial, demonstrating the specious nature of Edwards' Statement of Undisputed Facts. Second, Edwards' filing of correspondence and documents between Epstein's counsel and Federal prosecutors violates an Order entered in Jane Doe No. 2. v. Epstein, Case No. 08-80893-Marra/Johnson on January 5, 2011. (See D.E. 226) (Ex. A attached hereto). Pursuant to that Order, Edwards is required to seek leave of court before filing or making public the subject correspondence and documents. Edwards, however, did not seek leave of this Court before making public thousands of pages of confidential documents subject to the Federal Order. Third, evidence of a settlement or statements made during settlement negotiations are inadmissible to prove liability under §90.410, Fla. Stat. See Richardson v. State, 706 So. 2d 1349, 1355-1356 (Fla. 1998) ("Rule 3.172(h) and Section 90.410, Florida Statutes (1991), prohibit the admission of statements given during plea negotiations."); State v. Walters, 12 So. 3d 298, 303 (Fla. 3d DCA 2009) (error to admit e-mails exchanged during plea negotiations; exclusion of offers to compromise is based on ground that the evidence is irrelevant and public policy favors amicable settlements of disputes and the avoidance of litigation); Debiasio v. State, 789 So. 2d 1061, 2001 Fla. App. LEXIS 8039 (Fla. 4th DCA 2001) ( a letter from the defendant's attorney to the State's attorney stating that defendant was willing to accept responsibility for 20 EFTA00808045 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ what he had done was an offer to plead guilty that was inadmissible evidence under Ha. Stat. § 90.410). In the instant case, any and all evidence cited by Edwards regarding the plea negotiations between Epstein's counsel and the U.S. Attorney's Office must be stricken for the reasons set forth herein. THE SWORD AND SHIELD DOCTRINE DOES NOT SUPPORT SUMMARY JUDGMENT FOR EDWARDS Edwards contends that Plaintiff must be denied any affirmative relief regardless of the merits of his cause, because at his deposition taken in the instant case, Plaintiff refused to answer certain questions, invoking his Fifth Amendment privilege. (Mot. at 19-20). Edwards also argues that he is entitled to summary judgment because Plaintiff's assertion of the Fifth Amendment raises adverse inferences which conclusively establish that Plaintiff's claims are without merit. (Id. at 21-2). Edwards' arguments are wrong. First, Edwards misapprehends the nature and application of the "sword and shield" doctrine, which "embraces the rule `that a plaintiff may not seek affirmative relief in a civil action and then invoke the Fifth Amendment to avoid giving discovery in matters pertinent to the litigation.' DeLisi v. Bankers, Ins. Ca, 436 So. 2d 1099, 1100 (Fla. 4th DCA 1983) (quoting City of St. Petersburg v. Haughton, 362 So. 2d 681, 685 (Fla. 2d DCA 1978) (emphasis added)). See also Brancaccio v. Mediplex Mgmt. of Pon St. Lucie, Inc., 711 So. 2d 1206, 1208-1210 (Ha. 4th DCA 1998) (approving City of St. Petersburg and Village Inn Rest v. Aridi, 543 So. 2d 778,782 (Ha. 1st DCA 1989)), in which the First District agreed that "sanctions may be necessary where a plaintiff in a civil action invokes the Fifth Amendment privilege against 21 EFTA00808046 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ revealing relevant information in pretrial discovery." (emphasis added). The Fourth District explained in Brancaccio that the "Supreme Court has disapproved of procedures which require a party to surrender one constitutional right in order to assert another..." 711 So. 2d, at 1210. Thus, a "civil defendant [does not] have an absolute right to have the action dismissed any time a plaintiff invokes his constitutional privilege." Pursuant to the foregoing authorities, Plaintiff's claims may not be dismissed on summary judgment pursuant to the "sword and shield" doctrine because the information Edwards sought to elicit from Plaintiff at his deposition, and the answers Plaintiff declined to give in response to questions about his alleged misconduct and criminal activity, would not provide any information relevant to Plaintiff's claims or Edwards' defense of those claims. Plaintiff's allegations are based on the belief that Edwards inflated purported claims against Plaintiff and conducted discovery of high profile figures in the cases pending at the Rothstei

EFTA01730634.pdf

DataSet-10 Unknown 114 pages

Case Number: 50D-NY-3027571 Case Summary: Child Sex Trafficking investigation into Epstein, opened 12/08/2018. Epstein was indicted on 07/02/2019 and arrested on 07/06/2019. On 08/10/2019, FBI NY was notified Epstein committed suicide in his jail cell. Maxwell was indicted on 06/29/2020 and arrested on 07/02/2020. The Maxwell trial began on 11/28/2021. Maxwell was convicted on 12/29/2021 on S out of 6 counts. Maxwell was sentenced on 06/28/2022 to 20 years. In November 2024, the U.S. appeals court rejected Maxwell's request for en banc review. Maxwell requested an appeals extension to 04/10/2025. This investigation remains in Pending Inactive status. EFTA01730634 Evidence Report for Case: SOD-NY-3027571 Filtering on: Type(s):18 Item U Collected On Description 18146 7/22/2022 10:00 (U) ONE CELLOPHANE containing: NYC032395 - One (1)DVD-R containing image log files and FTK reports for system information on selected items. 16145 5/25/2022 14:00 (U) Red Rope Containing; NYC032391 - Three (3) LTO 6 tape cartridges containing an Arcserve backup of all digital evidence from Submission ID 219407. 18144 5/25/2022 14:00 (U) Red Rope Containing; NYC032392 - Two(2) LTO 6 tape cartridges containing an Arcserve backup of all digital evidence from Submission ID 215974. 18143 7/7/2019 3:00 (U) one (1) CD labelled "girl pits nude book C 18142 10/8/2021 13:00 (U) ONE REDROPE CONTAINING: (1) Envelope containing 1VHS tape, 2 cassette tapes & 4 micro cassette tapes 18141 10/8/2021 13:00 (U) ONE REDROPE CONTAINING: (1) Envelope containing 4 CD's 16140 10/8/202113:00 (U) (2) Bankers box containing various EPSTEIN related case materials 16139 6/29/2021 16:15 (U) ONE BOX CONTAINING: One pair of black women's cowboy boots, size 8 18138 8/12/2019 19:20 (U) ONE CELLOPHANE containing: Disk containing images of Matchmaker shred reconstruction 18137 8/28/2006 11:50 (U) ONE CELLOPHANE CONTAINING: (1) un-framed photo. 18136 1/26/2021 16:00 (U//FOUO) ONE RED ROPE containing: Highly confidential responsive material to include nude and semi nude images and videos from digital evidence items processed by CART. 16135 6/6/2019 12:00 (U) Box containing Ten yearbooks collected by FBI West Palm Beach Resident Agency 16134 8/28/2006 11:00 (U) One (1) peach massage table. 18133 8/28/2006 11:00 (U) One (1) green massage table (PBPD05.1024). 18132 8/28/2006 11:50 (U) One (1) beige massage table. 18131 8/28/2006 11:50 (U) One (1) brown massage table. 18130 8/28/2006 11:50 (U) One flat box containing one (1) large framed photo. 18129 8/28/2006 11:50 (U) One box containing four (4) framed photos. 18128 8/28/2006 11:50 (U) One box containing twelve (12) framed photos. 18127 8/28/2006 11:50 (U) One box containing five (5) framed photos 18126 8/12/2019 19:20 (U) One red rope containing: LS1 logbook 18125 8/12/2019 19:20 (U) One red rope containing:Daily Vessel Trip logs Feb 2, 2017 - Feb 16, 2017 16124 8/12/2019 19:20 (U) HP Tower S/N: CNV74213M3 Model: 570-p056 16123 8/12/2019 19:20 (U) Lenovo Tower S/N: 15330662UM1XEKGX 18122 8/12/2019 19:20 (U) Lenovo Tower S/N: M107YG6U Machine type: 9010 18121 8/12/2019 19:20 (U) Mac Desktop S/N: W89524C2SP1 model A1312 18120 8/12/2019 19:20 (U) HP Tower S/N: CNV716004Y Model N: 260-a010 18119 8/12/2019 19:20 (U) HP Desktop Tower S/N: CNV7160050 Model N: 260-a010 18118 8/12/2019 19:20 (U) Silver Mac desktop 16117 8/12/2019 19:20 (U) 6 Bay with 14668 drives S/N: MXQ824A1R 18116 8/12/2019 19:20 (U) One box containing Panasonic KX-TDE100 S/N: KX-TDA01049LCCD005398 EFTA01730635 18115 8/12/2019 19:20 (U) HP server with (4) 500 GB drives S/N: MXQ3220187 18114 8/12/2019 19:20 (U) Blue prints 16113 8/12/2019 19:20 (U) One cellophane containing:Boat trip log & employee lists 18112 8/12/2019 19:20 (U) Unifi server MacID: 1735K788A20463234-8uuu9F FCCID: SWX-UASPRO 18111 8/12/2019 19:20 (U) Unifi video M/N: UVC-NVR-2T8 MacID: 1829F84F6E426EA90 18110 8/12/2019 19:20 (U) One cellophane containing:Paper with passwords on both sides 18109 8/12/2019 19:20 (U) Unifi Cloud key M/N: UN-CK FCCID: SWX-UCCK IC 6545A-UCCK Mac ID: 1843KB4F6E4D30C69-dcRgm9 16108 8/12/2019 19:20 (U) CELLOPHANE containing Olympus Digital Voice Recorder 18107 8/12/2019 19:20 (U) Silver Mac desktop Model tt: A1311 S/N: W804736DDAS 16106 8/12/2019 19:20 (U) Dell Inspiron tower with power cord Reg Model: D19MQCHFA335 16105 8/12/2019 19:20 (U) One red rope containing:LSI & GSJ float Log 2019 18104 8/12/2019 19:20 (U) Box containing Shredded paper 18103 8/12/2019 19:20 (U) ONE CELLOPHANE CONTAINING; Apple iPod shuffle on watch band 18102 8/12/2019 19:20 (U) Silver Macbook Desktop with keyboard 18101 8/12/2019 19:20 (U) One cellophane containing:Photograph 18100 8/12/2019 19:20 (U) One cellophane containing:Employee contact list 1899 8/12/2019 19:20 (U) One red rope containing:Red Nikon Camera 1698 8/12/2019 19:20 (U) One box containing: Silver Desktop Mac with keyboard 1697 8/12/2019 19:20 (U) HP Laptop with charger S/N: CND81368V5 1896 8/12/2019 19:20 (U) Toshiba Laptop with charger 1695 8/12/2019 19:20 (U) One red rope containing:Remodeling documents for Island 1894 8/12/2019 19:20 (U) One cellophane containing:Handwritten notes on L.51 notepad 1893 8/12/2019 19:20 (U) One flat FedEx box containing: Photos, Photo negatives, letter 1692 8/12/2019 19:20 (U) One red rope containing:lsland blueprints, island photos, and documents 1891 8/12/2019 19:20 (U) One red rope containing:photo album of girl & Epstein 1890 8/12/2019 19:20 (U) One red rope containing:letter, photo album of girls, photos of island 1689 8/12/2019 19:20 (U) One cellophane containing:Document with names 1888 8/12/2019 19:20 (U) One cellophane containing:Employee contact list 1687 8/12/2019 19:20 (U) Silver Mac Desktop 1686 8/12/2019 19:20 (U) One red rope containing: Notepads with notes - LSI stationary with handwritten notes 1885 8/12/2019 19:20 (U) Silver Mac Desktop with mouse & keyboard S/N: CO2NMIMOFYI4 1684 8/12/2019 19:20 (U) Silver iPad Model A1567 S/N: DMPQL1RMG5Y in case 1683 8/12/2019 19:20 (U) CELLOPHANE containing Silver Wad Model A1567 S/N: DMPQL25NGSYPY in case 1882 8/12/2019 19:20 (U) RED ROPE containing Silver MacBook Pro S/N: C02QMOGUGWDP 1881 8/12/2019 19:20 (U) Silver Mac Laptop labeled "lE BIG LAPTOP" "BLACK BAG" in black bag S/N: W89111772QT 1680 8/12/2019 19:20 (U) Mac Desktop labeled "Kitchen Mac" - grey EFTA01730636 1879 7/11/2019 15:35 (U) One heat-sealed bag containing one yellow envelope mark dated 08/27/08 containing multiple smaller envelopes containing $17,115 USC (152 x $100, 35 x $50, 4 x $20, 6 x $10, 5x $5). 1878 7/11/2019 15:35 (U) RED ROPE CONTAINING: 4 binders with 68 discs inside 1877 7/11/2019 15:35 (U) One heat-sealed bag containing one small white envelope with writing "2000-5K" containing $4,400 USC (44 x $100). 1876 7/11/2019 15:35 (U) ONE CELLOPHANE CONTAINING; Austrian Passport with Epstein photograph 1875 7/11/2019 15:35 (U) RED ROPE CONTAINING: Two blue binders with 58 discs Inside 1874 7/11/2019 15:35 (U) CELLOPHANE containing Black hard drive 1873 7/11/2019 15:35 (U) CELLOPHANE containing Black hard drive 1972 7/6/201918:15 (U) One (1) silver IPad with serial number DLXQGM3KGMW3. 1871 7/6/201818:15 (U) ONE CELLOPHANE CONTAINING :One (1) black iPhone with IMEI number 357201093322785. 1670 7/11/2019 19:28 (U) One box containing: 1 Apple Desktop computer 1869 7/11/201919:28 (U) I Silver IPAD - 64GB 1868 7/11/201919:28 (U) 1 Space Gray Apple IPAD 1967 7/11/2019 19:28 (U) 1 Space Gray Apple IPAD 1866 7/11/2019 19:28 (U) One cellophane containing 1 Black Radioshack recorder 1865 7/11/2019 19:28 (U) One cellophane containing 1Silver Olympus recorder 1864 7/11/2019 19:28 (U) One cellophane containing 1 Sony BM-560 Recorder 1863 7/11/2019 19:28 (U) Box containing 45 Assorted Cd's 1862 7/11/201919:28 OA One red rope containing 1 Sony Vaio Laptop 1861 7/11/201919:28 (U) 1 Dell Precision Tower 5810 1860 7/11/2019 19:28 (U) One red rope containing:1 Seagate Barracuda 7200 harddrive 8068 1859 7/11/2019 19:28 (U) 1 MSI PC Computer IN A BROWN BOX 1858 7/11/2019 19:28 (U) One red rope containing:1 Sony Camera with black case 1857 7/11/2019 19:28 (U) 1 Gray Apple Desktop Computer with keyboard and mouse 1956 7/11/2019 19:28 (U) One cellophane containing 1 Seagate Backup Plus Portable Drive - ITB 1855 7/11/201919:28 (U) One cellophane containing one (1) White Apple 'Phone 5, 64GB. 1854 7/11/201919:28 (U) 1 Apple Desktop Computer with keyboard and mouse 1953 7/11/2019 19:28 (U) 1 Apple Desktop Computer with keyboard and mouse 1852 7/11/2019 16:28 (U) One cellophane containing: 1 SPIED 2014 Silver USB 1851 7/11/2019 16:28 111) One cellophane containing 1 Cruzer Guide 32GB USB 1850 7/11/2019 16:28 (U) One cellophane containing 1 Cruzer Guide 32GB USB 1849 7/11/2019 16:28 (U) One cellophane containing 1 Cruzer Guide 3268 USB 1948 7/11/2019 16:28 (U) One cellophane containing 1 Cruzer Guide 32GB USB 1847 7/11/2019 16:28 (U) One cellophane containing 1Blue EMTEC 16 GB USB 1946 7/11/2019 16:28 (U) One cellophane containing 1 EMTEC 16 GB USB 1945 7/11/2019 19:28 (U) One red rope containing:10 assorted cd's 1944 7/11/2019 19:28 (U) One cellophane containing 1 Silicone Power Micro SD Adapter with 16GB SD Card 1943 7/11/2019 19:28 (U) 1 DELL Machine 1842 7/11/2019 19: 8 (U) 1 Cube 9000 Siteserver, (BLACK/SILVER) 1841 7/11/2019 19:28 (U) 1 HP Compaq Machine 1840 7/11/2019 19:28 (U) One cellophane containing one (1) Mentor Media 32GB USB. 1839 7/11/2019 19:28 (U) One cellophane containing one (1) Data Traveler 4GB USB. 1938 7/11/201919:28 (U) One cellophane containing one (1) Data Traveler 4GB USB. 1837 7/11/201919:28 (U) One red rope containing:1 Seagate Path/100 Hard Drives 1836 7/11/2019 19:28 (U) One red rope containing: 1 Seagate Path/100 Hard Drives 1835 7/11/2019 19:28 (U) One red rope containing:1 Seagate Path/100 Hard Drives 1834 7/11/2019 19:28 (U) One red rope containing:1 Seagate Path/100 Hard Drives 1833 7/11/2019 19:28 (U) One red rope containing:1 Seagate Path/100 Hard Drives 1932 7/11/2019 19:28 (U) One red rope containing:1 Seagate Path/100 Hard Drives 1831 7/11/201919:28 (U) One red rope containing: 1 Seagate Path/100 Hard Drives 1830 7/11/201919:28 (U) One red rope containing: 1 Seagate Path/100 Hard Drives 1829 7/11/2019 19:28 (U) One red rope containing:1 Seagate Path/100 Hard Drives 1828 7/11/2019 19:28 (U) Silver Apple Desktop Computer with keyboard and mouse 1827 7/7/2019 3:00 (U) ONE BOX CONTAINING: 1 stuffed dog EFTA01730637 1B26 7/7/2019 3:00 (U) Box containing 2.1 inch black binders containing CD's and 13 loose CO's 1B25 7/7/2019 3:00 (U) ONE BOX CONTAINING: 2 white in color busts of female torsos 1B24 7/7/2019 3:00 (U) ONE BOX CONTAINING: 1brown bust sculpture of female breasts 1823 7/7/2019 3:00 (U) One red rope containing: 2 photos and 1album page with additional 2 photos 1B22 7/7/2019 3:00 (U) ONE BOX CONTAINING: 1blue box containing various Cd's 1821 7/7/2019 3:00 (U) Red rope containing 12 polaroid photos, 1 folder labeled' containing various photos/cd's 1B20 7/7/2019 3:00 (U) ONE BANKERS BOX CONTAINING: bundled photos and cd's from "Women Old Photos Box" 1B19 7/7/2019 3:00 (U) 10 black binders containing photos, cd's etc. 1818 7/7/2019 3:00 (U) 1blue in color bust of a female torso 1817 7/7/2019 3:00 (U) One red rope containing: 2 photos of female buttocks 1816 7/7/2019 3:00 fffI One box containing: 5 costumes and 1 wig 1815 7/7/2019 3:00 (U) ONE RED ROPE CONTAINI1 vibrator, 3 buttplugs, 1set of cuffs, I dildo, 1leash, 1 box of condoms, 1nurse cap, 1 stethescope 1814 7/7/2019 3:00 (U) ONE RED ROPE CONTAINING; (1) butt plug 1813 7/7/2019 3:00 (U) One box containing four (4) framed photos of naked females. 1812 7/7/2019 3:00 (U) ONE CELLOPHANE CONTAINING: 1 set of copper handcuffs and whip 1811 7/7/2019 3:00 (U) One (1) green massage table. 1810 7/7/2019 3:00 (U) One cellophane containing:3 sheets of paper- (1) photo depicting two girls, (2) cash disbursements 189 7/7/2019 3:00 (U) One cellophane containing:3 pages- (1) handwritten note Epstein letterhead, (2) page typed letter 188 7/7/2019 3:00 (U) One flat FedEx box containing: 3 photographs- (2) depicting Epstein with two females, (1) photo depicting two females 187 7/7/2019 3:00 (U) One red rope containing: 3 sheets of paper depicting photographs of a living room 186 7/7/2019 3:00 (U) One cellophane containing: 2-page handwritten letter Steven D. Small 185 7/6/2019 0:00 (U) Box containing one (1) set of Blueprints for residence 9 East 71st Street, New York, New York Stamped received 2003 184 5/29/2019 18:00 (U) ONE RED ROPE CONTAINING: 1Red Notebook 183 5/29/2019 18:00 (U) ONE RED ROPE CONTAINING: 10 Photographs 1B2 5/29/2019 18:00 (U) ONE RED ROPE CONTAINING: 17 Miscellaneous Financial Documents 181 5/29/2019 18:00 (U) ONE RED ROPE CONTAINING: 1Premier Day Planner EFTA01730638 Evidence Report for Case: SOD-NY-3027571 Filtering on: Type(s): 1D Item It Collected On Description 106 8/24/2020 7:00 (U) (NY-ERF#19236) Court Authorized Intercept Doc# 20-CRIM- 1281832 Facility-917-520-3106 Blu-Ray Discti 744655 105 8/3/2020 9:25 (U) 07/02/2020; One (1) original SD card and one (1) Blu Ray containing FLIR aerial surveillance footage of Bradford, NH on the aforementioned date. 104 5/7/2020 7:00 (U) (NY-ERF#18399) Court Authorized Intercept-Doc#20-CRIM-21340 Facility-917-520-3106 Disc#690612-R1 103 4/18/2020 7:00 (U) (NY-ERF# 18727) Court Authorized Intercept Doc#20-CRIM-81211 Facility-917.520.3106 Blu-Ray Disc#694397 102 2/4/2020 7:00 (U) (NY-ERF# 18309) Court Authorized Intercept Doc# 19-CRIM- 29845156 Facility-917-520-3106 Disc# 671455 1D1 8/20/2019 17:00 (U) Recorded Interview (Non-Custodial - Overt) DTD 8/13/2019 with Philadelphia EFTA01730639 Evidence Report for Case: SOD-NY-3027571, Filtering on: lA Type a Acquired On Serial a Serial Title Summary m nz 2025-03-10 2.4§ (U) Transport of Evidence Items 18136, (U) Chains of Custody 16144, 19145, and 19146 IA 11§ 2025-03-10 2.0§ Ili/Transport of Evidence Items 18136. (U) Ending Transport Photographs 16144, 16145, and 16146 M in 2025-0340 22¢ (U) Transport of Evidence items 18136, (U) Starting Transport Photographs 16144 16145 and 16146 IA 314 2025-02-27 71d (U) Transfer of Case Documents from the (U) Photos and Photo togs New York Field Office to the Washington Field Office IA III 2024-08-01 „2Q (U) Interview o (U) Agent Notes M 312 2022.11-02 696 (U//FOUO) Email Ira rid attachments from JEFFREY EPSTEIN m m 2022-05-26 9.22 (U) Mail Received from Epstein Residence (U) letter from former Epstein Estate; fake NY State Driver's license 1A 310 2022-03-07 687 (U) Phone interview wit 1U nterview notes LA 342 2021.12.11 18§ M 10/ 2021.11.24 OD (U -nterview notes lA E/2 2021.11.22 ¢7.2 IU nterview notes IA 306 2021-11-23 677 (U) Interview o (U) interview notes IA Ai 2021-11-05 J24 (U) Interview o (U) digital notes IA HA 2021.10.19 §7.2 (U) Interview o (U) Otgital notes, household manual IA 39/ 2021.11-02 EU (U) Phone conversation will(U)Notes M AU 2021.10.11 E2 (u) Call w (LiMi.:nes LA ni 2021.10.14 12 / 2 (U) Reimbursement of expenses incurred for (U) 794 trial M Ng 2021-06-23 fira (U) Reimbursement of expenses incurred for (U) Receipt trial 1A 222 2021-10-08 ft& (U) Interview o (U _nterview notes lA 298 2021.10-08 665 (U) Materials from Palm Beach Police (U) Property receipt Department IA 21j 2021-10-08 ifa (U) Materials from Palm Beach Police (U) Trash pull Department 1A 296 2021-10-08 665 (U) Materials from Palm Beach Police (U) Digital case files Department lA 295 2021-10-08 665 (U) Materials from Palm Beach Police (U) Subpoena Department lA 294 2021.10-08 664 U//FOU0 NT0C202I E-Tip Additional Victim U 755162_NY Reports Being Human Trafficked By Gislaine Maxwell M A Child (TP) lA Di 2021.10-08 MI U NTOC2020 352mtr01Information on a U 696289_NY Possible Accountant of Jeffrey Epstein. (NY) IA 292 2021-10-08 662 U//F0U0 NTOC2020 024srm01E-Tip: U 708478_NY Possible Human Trafficking in New York, NY. (NY) lA 291 2021-10-08 661 U USPS Mall Tipster - Information Related to U 664501 NY Jeffrey Epstein/Unnamed 29 YOA Jewish Female IA liQ 2021.10-08 gt2 U NTOC2020 195hmb02 Potential Sex U 658904_NY Trafficking by Greg Horvath and Jana Jaffe in New York, NY (NY) IA 2.92 2021.10-08 152 U Email regarding information for sale about U 603996_NY the Epstein Zorro Ranch IA 288 2021-10-08 U//FOUO NTOC2021Concerning Comments U 751864_NY b NY) EFTA01730640 IA 29/ 2021.06-23 931 (U) Reimbursement of expenses Incurred for (U) Receipt trial IA 286 2021-10-07 92 (U) Reimbursement of expenses Incurred for (U) FD-794 trial IA 285 2021-10.07 656 (U) Fed-Ex Delivery Confirmation (U) Fed-Ex Delivery Confirmation, 41864 0967 1500 IA 244 2021-09-02 O3 (U) Interview o September (U) NB Interview notes - 9.2.21 & Scan 2, 2021 shown to N8 IA 213 2021-09-17 92 (U) Meeting wit (U) Notes m 282 2021-05-18 651 (U)Interview o (U) notes & doncuments IA 281 2021-09-20 40 (U) Interview o (U) Emails fro IA a9 2021-09-20 Ng (U) Interview o ILI nterview notes IA 279 2021-05-20 642 (u) Interview o (U) Notes la 1.73 2021-09-27 e4 (U) Interview o (U) NOteS IA 277 2021-08-19 647 (U) Interview o (U) Notes IA lie 2021-07-23 09 (U)Proffer o (U) Documents shown tc IA lie 2021-07-23 " 40 (U) Proffer o (V nterview notes IA 224 2021-09-21 §4 (U) Service of subpoena. (U) Drivers license information for each individual. IA 2021-09-01 05 (U) Interview o (U) News article shown t Ill September 1, 2021 IA 222 2021-09-01 fdl (U) Interview o (U) Notes September I, 2021 IA 271 2021-06-02 942 (U) Interview o (U) Documents shown tcl== IA 2Z2 2021-06-02 Ai (U) Interview o IU nterview notes IA 269 2021-04-27 641 (U) Interview/Proffer o (U nterview notes IA la 2021-01320 IV (u) Interview ci (u) Notes IA aj 2021-08-12 4.22 (U) Notes IA 246 2021-08-19 fla (U) Interview of BARBARA DEGE0RGI0V (U) Notes IA 145 2021-05.14 al (U) Proffer o (U ntelsnew notes IA alt 2021-05-14 1152 (U)Proffer o (U) Documents shown I. IA Al 2021-09-02 ilk (U)Interview ci (U) Notes IA 2§2 2021478-30 Lia (U) Interview o August 30. (U) Notes 2021 IA al 2021-08-31 M (U) Interview o August 31. (U) Notes 2021 IA 20 2021-09-15 fin (U) Request to serve three trial subpoenas (U) Trial Subpoenas IA 242 2021-09-02 O2 (u) Interview co (t)) photobook IA M 2021-09-02 § (U) Interview o (U) Nude photo o IA az 2021-09-02 a (U)Interview o Cu) Items shown tc= tines) interview IA 251 2021-09-08 az (U) Interview o (U) Notes IA 24 2021-07-27 931 (U) Interview o (U terview notes July 27, 2021 IA 254 2021-08-11 630 (U) I ntenriew o (U) Notes IA ja 2021-09-14 M (U)Interview o (U) notes IA 251 2021-04-01 O9 (U) Interview o (U)Notes IA 251 2020-11-30 _927 (U) Interview o (U) Notes IA 250 2021-06-30 626 (U) Interview o (U) Messages pads IA 249 2021-06-30 626 (U) Interview co (U) notes IA S 2r 2021-08-04 Q24 (Uuterview 8/4/2021 (U)Notes IA 247 2021-06-28 623 (U) Interview o (U) Transcript IA 246 2021476.23 AZ1 (U) Interview o (U) Epstein phone contact IA 245 2021-06-23 623 (U) Interview o (U) Notes IA 244 2021-03-23 622 (U) Interview o (U) Notes IA 243 2021-07-06 616 (U) locate and Serve witnes (U) Trial Subpoena EFTA01730641 IA 242 2021-07-14 §li (U) Missouri Birth Certificate Identified and (U) Copy of FedEx shipment with obtained tracking number 774263190664 IA 241 2021-07-14 615 (U) Missouri Birth Certificate Identified and (V embed obtained Birth Certificate IA 240 2020-02-14 613 (U) Device Extraction - MDUS 13768 (U) Legal Authority for Device IA 232 2021-06-29 510 (U//FOUO) Collection of evidence in Austin, (U//FOUO) ED-597 Texas IA 238 2021-05-20 fg)/ (U) 1A Lab Report Material: Lab II 2021- (U) Lab N 2021-00S8S: 1 disk 00585 IA 237 2021-04.13 605 (U) Interview co (U) Photo provided b IA DJ 2021-00-13 i22 (U) Interview o fll aszlo interview notes 1A l25 2021-04-01 le (U) Interview o (U nterview notes IA a& 2021-03-30 EU (U l iotes IA al 2021-0547 EZ (U) 2021-00585.2 Questioned Documents (U) 2021-00585-2 QUESTIONED DOCUMENTS 2021-00585-2 1A.zip CASE COMMUNICATION LOG: CommunicationLog2021-00585.pdf CASE NOTE INTERFACE REPORT: CNI Questioned Documents (AFI Case Note (143683).p CASE FILES: 2021.00585 N1, Lead 17.pdf 2021.00585 Shipping Invoke Container C.pdf 2021.00585 41, LER, Serial 575.pd f 2021-D3585 Shipping Invoke Container B.pdf 2021-00585 41Check-In Notes.rtf CASE CHAIN OF CUSTOM IA IX 2021-03-19 596 (U) Interview o (U) s IA 231 2021-01-29 588 (U) Interview o (U) Interview Notes IA in 2021-03-03 ak (U) Interview o u) interview notes IA 222 2021433-03 222 (U) Interview o (U) Photographs provided via email by IA M 2021-01-21 21/2 (U) Interview o Day 3 (U) Photo from Myspace account IA 2,22 2021-01-21 a2 (U) Interview o Day 3 (U) Interview notes day 3 IA 226 2021-01-19 al (U) Interview o Day 1 (U) Interview notes day 1 la 225 202102-24 583 (U) Interview o (U) Interview notes IA 224 2021-02-11 582 (U) Interview notes IA 223 2021-02-08 581 (U) Interview notes IA 222 2020-10-14 584 (I)) Interview o (U) (mails IA 221 2020-10-15 580 (U) interview o (U) Statement referenced in interview IA 220 2020-10-14 580 (U) Interview o (U) Interview notes IA 312 2021-01.27 57 (U) Interview o (U) Interview notes IA in 20214)241 5.22 (u) introductory Conversation with (U) Notes IA 227 2021-01-20 273 (U) Interview o Day 2 (U) Interview notes day 2 EFTA01730642 IA ilk 2021-01-14 az (U) Interview o (U) Interview Notes IA 215 2020-09-25 571 (U) Interview o (U) Interview notes IA 214 2021-02-02 570 U) Interview o (U) Interview notes IA 213 2021-01-12 (U) Interview o (U) Interview notes IA 212 2020-10-28 568 (U) Interview o (U) Interview notes lA 211 2021-01-27 567 (U) Proffer o (U) Interview notes IA 210 2020-02-07 566 (U) Interview/Proffer o (U) Rodgers flight log IA 269 2020.10-07 555 (U) Interview/Proffer o (U) interview notes IA 208 2021-01-13 565 U) Interview o (U nterview notes IA 207 202009-10 564 (U) Interview o (U) Interview notes 1A 206 2020-10-09 563 U) Interview o (U) Interview notes IA 205 2021-01-19 $SA U a013.pdf (U)Chabad's involvement in U.S. Presidential pardon petitions and influences from Russia and Israel on President Trump and Jared Kushner LA 244 2020-10-15 556 (U) Call received from (U) notes 1A 203 2020-11.04 555 (U) Interview o (U) Interview notes IA 202 2020-10-29 554 (U) Interview o (U) Interview notes 1A 201 2020-08-13 552 (U)Interview o (U) Interview notes 1A NO 2020-06-19 551 U) Interview o (U) Interview notes 1A 199 2020-08-21 550 (U) Interview o (U) Interview notes IA 198 2020-08.22 549 (U) Interview o (U) Interview notes IA 197 202008-21 548 (U) Interview o (U) Interview notes 1A 196 2020.10-09 547 (U) Interview o (U) Interview notes IA 195 2020-08-17 545 (U) Interview o (U) interview notes LA 194 2020-10-09 545 (U) Interview o (U) Interview notes IA 191 2020-08-21 sa U) Interview o (U terview notes IA 192 202011.18 HZ (U) Victim Services Division • Case Support (U) latest contact information tracked Unit Assistance and updated by ODAG partners. IA 191 2020-08.24 541 (U) Interview o (U) Interview notes la Lw 2020-10-21 111 (U) Fund Reimbursement - Five 2TB Hard (U)10.21HD Receipt drives IA 119 2020.10-22 515 (U) Fund Reimbursement - Five 2TB Hard (0)10.22 HD Receipt drives IA 131 2020-10-09 5/5 (U) Fund Reimbursement • Five 2TB Hard (U)1O.9 HD Receipt drives IA IR 2020-06-19 §1.1 (U) Fund Reimbursement • 12 TB External (U) Receipt Hard Drive IA At§ 2020-08.26 U) Interview o (U) Interview notes IA 155 2020-0849 U) Interview o (U) Interview Notes IA 184 2020-08-11 (U) Interview o (U) Interview notes IA IN 2020-08-12 (U) Interview o (U) Interview notes IA 182 2020-07-17 500 (U)Interview o (.I-nterview notes IA 181 2020-07-07 49/ (U) Interview o (U) Interview notes IA .1.82 2020-0745 a§ (U) Interview notes IA 179 2020-07-15 495 U) Interview 0 (u) Interview notes IA 178 2020-07-27 488 (U//FOUO) Interview o (U//FOUO) Notes Re: Interview i: l n July 27, 2020. 1A IZZ 2020-08-04 ra8 U//FOU0) Interview o (U//FOUO) City of Maricopa Police Department Officer Report for D.R. 200722037 IA 1ZI 2020-07-28 im (U) Lead Request to Serve grand jury (U) Subpoena subpoen IA Uk 2020-07-28 ili U) Lead Request to Serve grand jury (U) Accurint ubpoen IA 174 2020-07-28 472 U) Lead Request to Serve grand jury (U) Subpoena subpoen IA la 2020-07-28 422 (U) Lead Request to Serve grand jury (U) Accurint subpoen IA 172 2020477-28 476 (U) Lead Request to Serve grand jury (U) Subpoena subpoen. IA 171 2020-07.28 raf (U) Lead Request to Serve grand jury (U) Accurint subpoen EFTA01730643 170 2020-07-27 475 (U) Date Submitted: 07/25/2020 10:08:31 (U)(U//FOU0) THE INFORMATION AM ET Transaction Number: 4D291278-35FF- CONTAINED HEREIN HAS BEEN 489A-A26C DETERMINED BY THE FBI TO BE PERTINENT TO & WITHIN THE SCOPE OF AN AUTHORIZED LAW ENFORCEMENT ACTIVITY & SHOULD BE CONSIDERED IN THE CONTEXT OF THE ASSESSMENT OR PREDICATED INVESTIGATION TO WHICH THE INFORMATION RELATES. PARTICULAR ATTENTION SHOULD BE GIVEN TO THE AUTHORIZED PURPOSE FOR COLLECTING & RECORDING THIS INFORMATION PURSUANT TO THE ATTORNEY GENERAL'S GUIDELINES FOR DOMESTIC FBI OPERATIONS & THE DOMESTIC INVESTIGATION & OPERATIONS GUIDE. THAT PURPOSE MAY BE SET FORTH IN THE FILE'S OPENING ELECTRONIC COMMUNICATION OR OTHER RELATED DOCUMENTS. IA 169 2020-07-21 469 (U) On 07/21/2020, at 2:17 a.m. Eastern (U) Screenshot of Reddit post by user limeade of birt r/maxwellhill IA 168 2020-07-14 468 (U//FOUO) Telephone Interview Of (U//FOUO) NYPD SVD Hotline Worksheet 1A 167 2020-07-02 467 (U) Arrest of GHISLAINE MAXWELL (U) Photo IA 1 2020-07-02 O2 (U) Arrest of GHISLAINE MAXWELL (U) Arrest warrant, arrest paperwork, notes IA 165 2020-07-08 450 (U//FOUO) Impersonation of FBI Agent (U//FOUO) Document and audio recording from Bradford (NH) Police IA 164 2020-07-13 449 (U//FOU0) Interview o IA 163 2020-07-13 445 (U) On 07/12/2020, at 3:12:08 PM Eastern (U) Graphic Capture of Viral Video. Time • ate of birth IA 162 2020-07-11 443 (U) On 07/11/2020, at 10:02 a.m. Eastern (U) screenshot of David McPhee's Quora Time, an anonymous tipster, Internet page Protocol( IA 101 2020-07-10 442 (U) On 07/09/2020, at 9:47 p.m. Eastern (U) Screenshots of Epstein's alleged Time mail address employees confession on YouTube and 4chan IA 160 2020-07-10 440 (U) On 07/10/2020, at 9:44 a.m. Eastern (U) Website www.kidsquest.com Time, an anonymous tipster, Internet Protocol OP IA 15.2 2020.07-10 14 (U) On 07/10/2020, at 9:22 a.m. Eastern (U) Screenshots from kidsquest.com Time, an anonymous tipster, Internet Protocol (IP 1A 158 2020-06.19 436 (U) Fund Reimbursement JU) Receipt 1/4 2.47 2020.07-06 413 (U) On 07/06/2020, at 10:19 AM Eastern (U) Reported Tweets to NTOC Time, the FBI Office of Public Affairs (OPA) IA 156 2020-06-25 428 (U//FOUO) Aerial photos of 3O1 Summer (U//FOUO) Aerial photos of 3O1 Summer Street Manchester by the Sea, Street Manchester by the Sea, Massachusetts 01944. Massachusetts 01944. IA 165 2020-07-07 422 (U) On 07/06/2020, at 12:33:51 PM Eastem (U) Screen shot of Imgur capture of the Time, an anonymous complainant, Email comment made b account IA 14 2020-07-02 12 (U//FOUO) Notes from IA IN 2019-07-17 41D5 (U) Information provided b (U) Photographs provided b IA 152 2019-10-25 4Q4 (U) Interview o n (U nterview notes 10/25/19 EFTA01730644 IA 11 2020-03-04 4Q3 u) Interview o (ll) Interview notes & documents provided b IA 150 202004-10 399 U) Interview o ill nterview notes IA 149 2020-02-07 398 (U) Interview o (U) Flight logs 1,4 ku3 2020-02-07 396 u) Interview o 01 nterview notes lA 147 2019-07-22 397 (U) Interview o (U -nterview notes IA 14,6 2019-11-21 326 (U) interview o a 11.21.19 (1) nterview notes IA . 431 2019-09-18 315 u) interview o ill nterview notes IA 144 2019-10-23 324 IU nterview notes IA 103 2019-10-23 313 U)Intennew o ill nterview notes IA 142 2019-o9-12 392 U)Intervie o (LI nterview notes IA 141 2019-08-26 391 U) I nterview o ill nterview notes IA an 2019-10-18 319 (U) Interview o (U) Two boxes of papers and media from PBPD 1A 139 2019-10-18 39Q (U) Interview o (U) Interview Notes IA 138 2019-09.12 389 (U) Interview o (U) Interview notes IA 137 2020-02-28 388 (U) Interview o (U) Interview Notes IA all 2019-10-23 187 ((U) Interview o (U) Interview Notes & police report IA US 2020-02-26 316 U) I nterview o (U)Interview notes IA 134 2019-10-24 385 U) Interview o (U) Photo provided b nd her attorneys IA 133 2019-10-24 385 (U) Interview o (U) Interview notes IA 132 2019-12-04 3.. (U) Proffer o (U nterview notes Interview 42 IA 131 2019-11-26 211 U) Proffer o (U) interview notes ntentiew NI la 130 2019-10-11 382 (U) Interview o n ill nterview notes 10/11/2019 IA 129 2020-02-05 380 U) Pass information to Swedish authorities (U-02 or informational purposes. IA ail 2019-11-04 AZ2 U) Interview o (U) Interview Notes IA 122 202002-05 RI (U) Share information with Swedish Ili 02 Authorities IA 2020-02-27 377 (U) Interview o (U nterview notes 1A 125 2019-08-13 376 (U) Interview o (U) Photo gook IA AZI 2019-08-13 376 u) Interview o (U) Interview notes IA 123 2020-02-05 315 (U) Interview o (U) Interview notes IA 122 202001-14 374 (U) Interview o (U) UIf interview

EFTA02109053.pdf

DataSet-10 Unknown 2 pages

To: From: Sent: Wed 4/9/2014 10:48:52 AM Subject: Re: Jeffrey Epstein 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 guests here on the island? If so, what is the • password? On Apr 8, 2014 2:19 PM, wrote: > tremendous. thanks > On Apr 8, 2014, at 3:16 PM, Greg Wyler wrote: » My cell is: >> See you soon. >> Ori•inal Messa » From: >> Sen : » 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! >> >> >> 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, wrote: EFTA_R1_00728010 EFTA02109053 >>> 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_00728011 EFTA02109054

EFTA01203361.pdf

DataSet-9 Unknown 33 pages

Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 Ill...II...1..1.1 1111.1 Bill To: JEGE LLC Invoice Number: INV14-00077 Account Code: JEGEE001 M. Number: Job Number: N212JE Payment Type: Direct Billing Payment Terms: Direct Billing Ins nice Date: 03/11/2014 Exchange Rate: 1.000000 USD INVOICE SUMMARY FOR WORK ORDER NUMBER: 23588 Registration Number: N212JE Time & Materials Flat Rate Total Labor: 14,559.50 USD 19,180.00 USD 33,739.50 USD Pans: 39,937.75 USD — 39,937.75 USD Services: 16,867.88 USD - 16,867.88 USD Misc Charges: 190.02 USD — 190.02 USD Freight: - - 1.052.87 USD Total: 71,555.15 USD 19,180.00 USD 91.788.02 USD Consumable Fees: 1,012.19 USD Subtotal: 92,800.21 USD Total: 92,800.21 USD HAW WorkOrderPreliminaryInvoicespt Page 1 of 33 Printed on 03/112014 at 1:22:05PM EFTA01203361 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WO a: 23588 Invoice Number: INVI4-00077 Item: 1. G-IV N2121E Miscellaneous Charges Part/Model 4: G-IV Item Serial Number: Time & Materials 85.90 USD Registration Number: N212JE Aircraft Serial Number: 1085 Discrepancy: 1.1. NOTE : Initial Down Payment 56,700.00 Paid (AMEX) 1/20/2014 Resolution: NOTE : Initial Down Payment 56,700.00 Paid (AMEX) 1/202014 Discrepancy: 1.4. Send customers repaired 42 CDU unit to Gulfsweam service center PHI for installation Resolution: Send customers repaired 42 CDU unit to Gulfstrcam service center PHI for installation Time & Materials Flat Rate Total Freight: 85.90 UM) 85.90 UM) Total: 85.90 USD 0.00 USD 85.90 USD Services: Ref. No. Description Quantity Sell Price Extended 1.4 41 Procure the services of Honeywell to repair Display controller 1.00 0.00 USD 85.90 USD Part Ref: 7007540-946 CONTROLLER, DISPLAY Serial Numbens) 91040534 Freight: 85.90 USD HAW WorkOrderPreliminaryInvoice.rpt Page 2 of 33 Printed on 03/11/2014 at 1:22:13PM Rel:5 EFTA01203362 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 Bill To: JEGE LLC W00: 23588 Invoice Number: INV14-00077 Item: 2. G-IV N2121E Inspection Aircraft Arrival Date: 01/26/14 A/C HRS: 8652.5 Part/Mndel SS: G-IV LNGS: 4012 Item Serial Number: Time & Materials 825.00 USD Registration Number: N212JE Aircraft Serial Number: 1085 Disc repa no!, 2.1. Complete CMP maintenance cards. update flight logs and maintenance log books in compliance with air carrier maintenance / inspection program. Resolution: Accomplished inspectors paperwork as required on the following dates, 01/28/14, 01/29/14, 01/31/14, 02/10114. 2117/14.2118114, 2/19/14, 2124/14. Time & Materials Flat Rate Total Labor: 770.00 USD 770.00 USD 'Total: 770.00 USD 00 I ND 770.00 USD Labor labor Billing Type Hours Type Hours Rate Amount Time and Material ST 8.00 n 111.111) 880.00 USD 880.00 USD Discrepancy: 2.2. Accomplish an incoming preliminary inspection as roquirod. Accomplish a hidden inspection if applicable. Resolution: Accomplished an incoming preliminary inspection as required. All work performed I/A/W Hawthorne Global Aviation Services repair station procedures manual on the following dates: 01/27/14 Time & Materials Flat Rate Total Labor: 55.00 USD 55.00 USD Fetal: 55.00 USD 0.00 USD 55.00 USD labor: Labor Billing Type Hours Type Hours Rate Amount Time and Material ST 0.50 (a) 110.00 55.00 USD 55.00 USD HAW WorkOrderFreliminaryinvoicc.rpt Page 3 of 33 Printed on 03/112014 at 1:22:13PM aer.5 EFTA01203363 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WO ft: 23588 Invoice Number: INV14-00077 Item: 4. G-IV N2121E Discrepancies Part/Model 4: G-IV Item Serial Number: Time & Materials 74,524.07 USD Registration Number: N212JE Aircraft Serial Numher: 1085 Disc rcpa : 4.1. Replace left engine vibration isolators: 712061,712062,712063, 712064 Resolution: Removed top left engine cowling for access to fwd. and aft. engine isolators. Removed and replaced fwd and aft engine isolators with "new" isolators. All work done I/AAV GIV MM Ref: 71-01-00 and CMP Codes 712061: 712062; 712063; 712064 Re-installed left top engine cowling I/A/W GIV MM Reft:71-02-00 2/11/2014 WJF Time & Materials Flat Rate Total Labor: 0.00 USD 2,575.00 USD 2,575.00 USD Parts: 8,044.52 USD 8,044.52 USD Semites: 2,024.00 USD 1024.00 USD Freight: 62.00 USD 62.00 USD Total: 10,13032 USD 2,575.00 USD 12,705.52 USD Labor: labor Billing Type Hours Type Hours Rate Amount Flat Rate 2,575.00 USD 2,575.00 USD Parts: Ref. No. Part number Description Quantity Sell price Extended 4.1 #1 94756-04 ISOLATOR 2 2,012.89 USD 4,087.78 USD Serial Numbeitsi 6743; 6771 Freight: 62.00 USD 4.142 94756-13 ISOLATOR. AFT 2 2,009.37 USD 4,018.74 USD Serial Number(s1 6654: 6641 Services: Ref. No. Description Quantity Sell Price Extended 4.1 #1 Procure the services of Dallas Airmotive to assist in isolator 1.00 2,024.00 USD 2,024.00 USD change HAW WorkOrderPrchminaryInvoicc.rpt Page 4 of 33 Printed on 03/11/2014 at 1:22:13PM Rai EFTA01203364 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WO a: 23588 Invoke Number: INV14-00077 Discrepancy: 4.2. Replace right engine vibration isolators: 712065.712066, 712067, 712068 Resolution: Removed top right cowling for access to fwd and aft engine isolators. Removed and replaced fwd and aft engine isolators with 'new' isolators. All work done I/AAV GIV MM Ref: 71-01-00 and CMP Codes: 712065: 712066; 712067: 712068 Re-installed right top engine cowling 1/AAV G1V MM Ref: 71-02-00 2/11/2014 WJF Time & Materials Flat Rate Total Labor: 0.00 USD 2,575.00 USD 2,575.00 USD Parts: 8,044.52 USD 8,044.52 USD Freight: 62.00 USD 62.00 USD Total: 8,106.52 USD 2575.00 USD 10,68152 USD Labor: Labor Billing Type Hours Type Hours Rate Amount Flat Rate 2.575.00 USD 2.575.00 USD Park: Ref. No. Part number Description Quantity Sell price Extended 4.2 NI 94756-04 ISOLATOR 2 2,012.89 USD 4,087.78 USD Serial Number(s) 6746; 6767 Freight: 62.00 USD 4.2 #2 94756-13 ISOLATOR. AFT 2 2,009.37 USD 4,018.74 USD Serial Numberki 6569; 6566 HAW WorkOrderPreliminaryInvoice.rpt Page 5 of 33 Printed on 03/1172014 at 1:22:13PM Reis EFTA01203365 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WON: 23588 Invoice Number: INV14-00077 Discrepancy: 4.3. Replace all Left engine Upper Pylon board seals except forward one. Resolution: Pylon board removal in work. 02/01/14 JR Removed all left engine upper pylon panel assemblies, as required. During removal, noticed the forward upper panel assembly seal needs to be changed. 02/0412014 EW Drilled oft' wom pylon seals from engine pylon boards. Located. cut and trimmed new seals and riveted seals to pylon boards as required. 02/14/2014 CF Reinstalled all left engine upper pylon panel assemblies, after replacement of pylon seals, as required. Installed panels with all new hardware. No discrepancies noted at this time. 02/14i2014 EW Time & Materials Flat Rate Total Labor: 0.00 USD 3,000.00 USD 3,000.00 USD Parts: 1,738.62 USD --- 1.738.62 USD Freight: 63.42 USD 63.42 USD Total: 1,802.04 USD 3,000.00 USD 4,802.04 USD Labor: Labor Billing Type Hours Type Hours Rate Amount Flat Rate (a 3,000.00 USD 3,000.00 USD Parts: Ref. No. Part number Description Quantity Sell price Extended 4.3 NI NAS1921N104-06 RIVET, HUCK 50 3.16 USD 171.29 USD Freight: 13.29 USD 4.3 #3 1159SCP474-1I SEAL 3 21.90 USD 115.83 USD Freight: 50.13 USD 4.3 #6 1159SCP474-I I SEAL 5 21.90 USD 109.50 USD 4.3 #7 1159SCP467-1I SEAL 1 1,382.42 USD 1,382.42 USD 4.3 #9 212-1/4A T1P,APEX 5/16 HIGH 2 11.50 USD 23.00 USD TORQUE HAW WorkOrderPreliminaryInvoice.rpt Page 6 of 33 Printed on 03/11/2014 at 1:22:13PM Rel.5 EFTA01203366 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WO #: 23588 Invoke Number: INV14-00077 Discrepancy: 4.4. Replace all right engine Upper Pylon seals. Resolution: Pylon board removal in work. 02/01714 JR Removed all right engine upper pylon assemblies, as required. During removal of the upper pylon assemblies, noticed seal on forward pylon was replaced previously. 02/04/2014 ENV Drilled off wom pylon seals from engine pylon boards. Located, cut and trimmed new seals and riveted seals to pylon boards as required. 02/14/2014 CF Reinstalled all right engine upper pylon panel assemblies, after replacement of pylon seals, as required. Installed panels with all new hardware. No discrepancies noted at this time. 02114/2014 EVe Time & Materials Flat Rate Total Labor: 0.00 USD 3,000.00 USD 3,000.00 USD Parts: 2,840.72 USD --- 2.840.72 USD Freight: 86.41 USD 86.41 USD Total: 2,927.13 USD 3,000.00 USD 5.927.13 USD Labor: Labor Billing Type Hours Type Hours Rate Amount Flat Rate (a 3,000.00 USD 3.000.00 USD Parts: Ref. No. Part number Description Quantity Sell price Extended 4.4 #1 NASI921M04-06 RIVET, HUCK 50 3.16 USD 158.00 USD 4.4 #4 I I59SCP474-1I SEAL 5 21.90 USD 195.91 USD Freight: 86.41 USD 4.4 #5 I I59SCP467-12 SEAL 1 1,036.82 USD 1,036.82 USD 4.4 #6 I I59SCP470-12 SEAL 1 1,536.40 USD 1,536.40 USD HAW WorkOrderPreliminaryInvoice.rpt Page 7 of 33 Printed on 03/11/2014 at 1:22:13PM Rel.5 EFTA01203367 Hawthorne Global Aviation Services Preliminary Invoice March 11,2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WO 6: 23588 Invoice Number: INV14-00077 Discrepancy: 4.5. Aircell Wi-Fi is intermittent Resolution: ATG system requires a maintenance port to be installed to facilitate troubleshooting of system. Installed maintenance port at ATCi4000 transceiver as per AIRCELL ATG4000 Installation Manual pan no. D13485 Revision F May 2013.02/04/2014 JS Contacted AIRCELL to inform them of the troubleshooting that was accomplished and they recommenced checking the AFT air to ground antenna cables and bonding of antenna to structure. Bonding check revealed poor electrical bonding to structure. Removed AFT antenna S/7.1411 505 and found corrosion on antenna to spacer mounting surfaces. Cables to AFT air to ground antenna checked normal. Requires antenna gasket, antenna replacement, and cleaning of spacer to aircraft skin mounting surfaces. Checked FWD antenna for bonding. Found electrical bonding insufficient. Removed FWD air to ground antenna SIN 411515 and found gasket missing between antenna and spacer. Mating surfaces between aircraft skin and spacer need cleaning. 02/05/2014 JS Cleaned mating surfaces on adapter spacers for FWD and AFT ATCi air to ground antennas and treated with aladinc. Installed gaskets P/N 13121 at FWD and AFT adapter spacers and installed air to ground antennas ref AIRCELL Antenna Installation Manual 800-10355. FWD antenna is P/N 12949 SIN 411515. AFT antenna is P/N 12949 Sal 443686. Accomplished Ani ground test ref ATG4000 Installation Manual pan number Dl 3485 Rev. F, May 2013. 02/06/2014 JS Time & Materials Flat Rate Total Labor: 1,320.00 USD 1,320.00 USD Parts: 3,732.99 USD 3,732.99 USD Freight: 76.03 USD 76.03 USD Total: 5,129.02 USD 0.00 USD 5,129.02 USD Labor: labor Billing "Type Hours Type Hours Rate Amount Time and Material ST 12.00 (a 110.00 1.320410 USD 1.320.00 USD Parts: Ref. No. Part number Description Quantity Sell price Extended 4.5 #1 I> 12949 Aircell Air-to-Ground I 3,328.00 USD 3,328.00 USD Antenna Serial Number(s) 443686 4.5 N2 PI3121 Gasket, Antenna, 2 164.00 USD 328.00 USD Air-to-Ground 4.5 #3 ECF504-.SC6 DELUXE PANEL COUPLER I 30.35 USD 106.38 USD KIT Freight: 76.03 USD 4.5 #4 PS870B1/2 SEALANT, 6OZ. I 46.64 USD 46.64 USD HAW WorkOrderPreliminaryInvoice.rpt Page 8 of 33 Printed on 03/11/2014 at 1:22:13PM Rel:5 EFTA01203368 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 DM To: JEGE LLC WO": 23588 Invoke Number: RW14-00077 Discrepancy: 4.6. Electronic checklist needs to be updated Co reflect revisions in AFM Resolution: Removed fault warning computers ref MM 31-02-0l to gain access to checklist modules. FWC No. I is P/N 7007484-905 SIN 88090305. FWC No. 2 is P/N 7007484-905 S/N 88090300. Removed checklist module from each FWC ref MM 31-31-02-01 page 443. Checklist module No. 1 is PIN 7010405-903 SIN 89030228. Checklist Module No. 2 is P/N 7010405-903 SIN 89030337. Checklist modules sent to Upstream Lincoln, CA for programming. 02+04/2014 DJS Received checklist modules in repaired condition and installed in Fault Warning Computers ref MM 31-02-01 page 443. Checklist module PIN 7010405-903 SIN 89030228 installed in FWC PIN 7007484-905 SIN 88090300. Checklist module PIN 7010405-903 SIN 89030337 installed in FWC PIN 7007484-905 SIN 88090305. Reinstalled FWC No. I and No. 2 into their original positions ref MM 31-02-0I. Accomplished operational check. All ops and indications normal. 02/10/2014 JS. Time & Materials Flat Rate Total Labor: 759.00 USD 759.00 USD Services: 3,450.00 USD — 3,450.00 USD Misc Charges: 94.25 USD 94.25 USD Freight: 116.72 USD 116.72 USD Total: 4,419.97 USD 0.00 USD 4,419.97 USD Labor: Labor Billing Type Hours Type /loon Rate Amount Time and Material ST 6.90 ® 110.00 759.00 USD 759.00 USD Services: Ref. No. Description Quantity Sell Price Extended 4.6 #1 Labor 1.00 1,725.00 USD 1,783.36 USD Part Ref: 7010405-903 Checklist Module Serial Number(s) 89030228 Freight: 58.36 USD 4.6 #2 Labor 1.00 1,725.00 USD 1,783.36 USD Part Ref: 7010405-903 Checklist Module Serial Numbeds1 89030337 Freight: 5826 USD Miscellaneous Charges: Ref. No. Miscellaneous Charge Amount 4.6 #1 Outbound freight charges for shipment to gulfstrcam to repair PIN 7010405-903 S/N 89030228 & 94.25 USD S/N 89030228 VIA ups Next Day Air tracking I187X4270157411930 HAW WorkOrderPreliminaryInvoice.rpt Page 9 of 33 Printed on 03/11/2014 at 1:22:13PM Rel.5 EFTA01203369 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: JEGE LLC WO #: 23588 Invoice Number: INV14-00077 Discrepancy: 4.7. Reposition APU Hobbs meter for easy viewing Resolution: Opened APU enclosure. Repositioned APU Hobbs meter for easy viewing. Ups checks good. Closed APU enclosure. 1/24/2014 W.11, Time & Materials Flat Rate Total Labor: 440.00 USD 440.00 USD Total: 440.00 USD 0.00 USD 440.00 USD Labor: Labor Billing "Type Hours Type Hours Rate Amount Time and Material ST 4.00 €0 110.00 440.00 ISD 440.00 ISD Discrepancy: 4.8. Galley sink will not drain overboard Resolution: Filled sink with water, sink drains properly at this time. No further action taken. 2/4/14O1 Time & Materials Flat Rate Total Labor: 220.00 USD 220.00 USD Total: 220.00 USD 0.00 USD 220.00 USD Labor: Labor Billing 'Type Hours Type Hours Rate Amount Time and Material ST 2.00 n 110.00 220.00 I M) 220.00 Util) Discrepancy: 4.9. Copilots Oxygen mask audio inop. Resolution: Trouble shot, found wire on oxygen mask audio jack broken, do to wire being too short. Rerouted wire harness and reinstall wire. ops. check audio on oxygen mask, operational check good. Time & Materials Flat Rate Total Labor: 220.00 USD 220.00 USD Total: 220.00 USD 0.00 USD 220.00 USD Labor: Labor Billing Type Hours Type Hours Rate Amount Time and Material ST 2.00 qe 110.00 220.00 USD 220.00 USD HAW WorkOrderPreliminarylnvoice.rpt Page 10 of 33 Printed on 03.112014 at I:22:13PM EFTA01203370 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: MGR LLC WO I*: 23588 Invoice Number: INV14-00077 Discrepancy: 4.10. During LH and RH engine upper pylon board removal found hardware paint filled, frozen and stripped. Resolution: Hardware removal in work. 02001/014 JR All hardware removed at this time, as required. Ordered all new hardware. 02/04/2014 EW Reinstalled all upper pylon panels with all new hardware. See attached documentation. 02114/2014 EW Time & Materials Flat Rate Total Labor: 571.00 USD 571.00 USD Parts: 1.148.66 USD 1.148.66 USD Total: 1.719.66 USD 0.00 USD 1,719.66 USD Labor: Labor Billing Type Hours Type Hours Rate Amount Time and Material ST 3.50 (a 110.181 385.00 USD Time and Material OT 1.20 ot 155.00 186.00 USD 571.00 USD Parts: Ref. No. Part number Description Quantity Sell price Extended 4.1041 NAS1580V3T3 SCREW 18 4.62 USD 83.16 USD 4.1002 NAS1580V3T4 SCREW 140 532 USD 828.80 USD 4.1043 NAS1580V3TS SCREW 30 7.89 USD 236.70 USD HAW WorkOrderPreliminaryInvoicespt Page 11 of 33 Printed on 03/11/2014 at 1:22:13PM Rel:5 EFTA01203371 Hawthorne Global Aviation Services Preliminary Invoice March 11,2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: MGR LLC WO It: 23588 Invoke Number: INV14-00077 Discrepancy: 4.11. Replace Cockpit Air Circulation Silencer Resolution: Replaced cockpit air circulation silencer with repaired unit IlA/W Gulfstream AMM 21-00-00. No further discrepancies noted at this time. 02/102014 EW Time & Materials Flat Rate Total Labor: 1,595.00 USD 1,595.00 USD Pans: 1,598.42 USD 1,598.42 USD Freight: 138.45 USD 138.45 USD Total: 3,331.87 USD 0.00 USD 3,331.87 USD Labor: labor Billing Type Hours Type Hours Rate Amount 'lime and Material ST 14.50 (7) I 10A/0 1.595,110 USD 1395.00 USD Parts: Rd. No. Part number Description Quantity Sell price Extended 4.11 01 II59ACI0I 14-1 Silencer 1,598.42 USD 1,736.87 USD Serial Number(s) 445302 Freight: 138.45 USD HAW WorkOrderPreliminaryInvoice.rpt Page 12 of 33 Printed on 031L2014 at 1:22:13PM n. < EFTA01203372 Hawthorne Global Aviation Services Preliminary Invoice March 11, 2014 2221 Smithtown Avenue Ronkonkoma, New York 11779 United States Telephone: 631-738-9880 Fax: 631-738-9878 BM To: MGR LLC WO 23588 Invoice Number: INVI4-00077 Discrepancy: 4.12. Comply With ASC No. 381; Wing Anti-Ice Heated Wheel Well Resolution: Complied with ASC No. 381; Wing Anti-Ice Heated Wheel Well. Removed left and right wing access panels. Drilled new louver panels to left and right wings. Countersunk and &burred louver panels. Installed louver panels with new hardware and sealed. Fitted new doublers to BL 0.00 And match drilled using existing holes. Riveted new doubler panels in place and top sealed. Installed all panels removed for mod..installation. All work done I/A/W Oulfstream ASC No. 381 Ref; ATA 30 Ice and Rain Protection. 2/1612014 WJF

EFTA02109393.pdf

DataSet-10 Unknown 1 pages

To: From: Sent: ue :56:25 PM Subject: Re: Jeffrey Epstein thx On Apr 8, 2014, at 10:36 AM, Larry Visoski wrote: > 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" 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, wrote: >> Hello Greg...Jeffrey c e n 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_00728605 EFTA02109393

EFTA00431510.pdf

DataSet-9 Unknown 3 pages

From: Lesley Groff <1 To: emad hanna Subject: Re: JE Date: Wed, 29 Jun 2011 20:03:06 +0000 you bet :) On Jun 29, 2011, at 4:01 PM, emad hanna wrote: great thanks Les Emad Hanna Project Controller HBRK Associates 301 East 66th St Suite IOF New York, NY 10065 Cell LSJ St. NY Fax On Jun 29, 2011, at 3:52 PM, Lesley Groff wrote: ok, got the fax...it's coming to you now! I am going away July 18-20 with Ike for business..., but JE will be here all next week so I will be here! You will see the days JE is on the island..i have written in where he is each day of every month...you will see the day's he flies to and from as well...very self explanatory!! On Jun 29, 2011, at 3:49 PM, emad hanna wrote: my fax # is listed below Are you going a vacation? Thank you Emad Hanna Project Controller HBRK Associates 301 East 66th St Suite IOF EFTA00431510 New York, NY 10065 Cell LSJ St. 5 NY Fax On Jun 29, 2011, at 3:46 PM, Lesley Groff wrote: oh my...this sounds like quite the project! Give me your fax number and I will fax you what I have. I can tell you were past records are and you can have a look if you like..I don't think I will be back in the office for a few weeks....the 2010 Flight Logs are on top of the File cabinet in my part of the office (the tall file cabinets) the Binder is clearly labeled "Flight Logs"...I think there may even be more binders up there with flight log info as well...take a look... send me your fax # :) On Jun 29, 2011, at 3:37 PM, emad hanna wrote: Would you have the specific days for this year? And once your back here can you see if you can find any older records? Thank you Emad Hanna Project Controller HBRK Associates 301 East 66th St Suite IOF New York, NY 10065 Cell LSJ St. NY Fax On Jun 29, 2011, at 3:31 PM, Lesley Groff wrote: I'm sure there are records that go back years...some may be in the office over there and some records could be in storage...I have here at JE's house only the days for this year (2011) As of 6/15/11 he spent 36 days on lsj EFTA00431511 On Jun 29, 2011, at 3:25 PM, emad hanna wrote: Hi Lesley, How far back do you have a record of JE days on LSJ? Thank you Emad Hanna Project Controller HBRK Associates 301 East 66th St Suite IOF New York, NY 10065 Ccl LSJ St. NY Fax EFTA00431512