DataSet-9
Unknown
16 pages
Page 1
CIAL CIRCUIT
IN THE CIRCUIT COURT OF THE 15th JUDI
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.
Plaintiff,
- vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF JEFFREY EPSTEIN
Wednesday, September 2, 9
10:10 - 10:15 a.m.
205 South Australian Avenue
Suite 1400
West Palm Beach,Florida 33401
Reported By:
Jeana Ricciuti, RPR, FPR, CLR
Notary Public, State of Florida
• Certified Copy
Prose Court Reporting Agency, Inc.
PROSE COURT REPORTING AGENCY, INC. (561) 83 -7506
(561) 832-7500
Electronically signed by Jcana Ricciuti (601-280-428-9381) 4a4ted77-isb79-43sg-s9c0.eos4iocd3szt
381)
Electronically signed by Jeana Ricelutl (601.280428-9
EFTA00726543
1 Defendant, Jeffrey Epstein.
2 MR. GOLDBERGER: Jack Goldberger on behalf of
3 Jeffrey Epstein.
COURT REPORTER: Sir, would you raise your
4
5 right hand, please.
MR. GOLDBERGER: Wait, wait. We've got
6
7 someone.
COURT REPORTER: I'm sorry.
8
MR. WILLITS: Yes. Richard Willits on behalf
9
10 of
- - -
11
12 Thereupon, •
13 (JEFFREY EPSTEIN)
rmed, was examined
14 having been first duly sworn or affi
15 and testified as follows:
16 THE WITNESS: Yes, I do.
17 DIRECT EXAMINATION
18 BY MR. KUVIN:
19 Q. Could you please give us your name.
20 A. Jeffrey Epstein.
what's been
21 Q. Is it true, sir, that you have,
22 described, as an egg-shaped penis?
23 MR. PIKE: Form, vague, indefinite, and I'm
Mr. Kuvin,
24 going to give you the first warning,
only
25 that these types of questions are not
LC================ral
(561) 832-7506
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
381)
Electronically signed by Jeana Fticcial (601.280-428.9 4a4f907-ab794388-a9t0-eakiffic431521
Electronically signed by Jeana Riccluti (601-280-4284381)
EFTA00726544
Page 6
er to
1 argumentative, but directed in a mann
7. embarrass Mr. Epstein. If you continue with this
deposition
3 type of questioning, I'll adjourn the
4 immediately.
S BY MR. KUVIN:
nt's
0 Q. Sir, according to the police departme
ribed your
probable cause affidavit, one witness desc
erect, it was thick
8 penis as oval shaped and claim, when
small --
9 towards the bottom but was thin and
10 MR. PIKE: We're stopping it now..
11 BY MR. KUVIN:
12 Q. --*towards the head portion, and called it
but as
13 egg-shaped. Those are not my words, I apologize,
14 Mr. --
15 MR. PIKE: The depo is now adjourned.
16 BY MR. KUVIN:
is
17 12. -- as Mr. Critton has stated, that this
18 a --
MR. PIKE: Thank you, Mr. Kuvin. Let's go.
19
MR. GOLDBERGER: All right.
20
I'm willing to continue. I'd
21 MR. KUVIN:
22 hate
23 MR. GOLDBERGER: Let me --
24 MR. KUVIN: to call him back.
MR. GOLDBERGER: Let me go on the record here.
25
PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
(561) 832-7500
Electronically signed by Jeana Ftlotion (601.280.428.9381) 4a419d77-ab79-43a8-a9c0-cc8410cd3521
Electronically signed by %Wane Ricetut% (601-280428.9381)
EFTA00726545
Page 7
Jack Goldberger on behalf of
Jeffrey Epstein.
2 We have tried to cooperate
in setting this
3 deposition; we want it to be
a meaningful
4 deposition for you. For the first question to
be a
question that serves no oth
er purpose other than
embarrass Mr. Epstein is jus
t totally unethical,
7 it's improper and it really
irritates me. We gave
8 you a warning where we said
don't do that again,
9 Spencer, and you continued
to do it.
10 I agree with Mr. Pike tha
t the deposition is
11 terminated at this point. If we want to go to
12 court and argue this, we'll
be happy to do it; I'm
13 sure we will. But we gave you a warning not
to do
14 that, and you did it, and you
chose to do it. So,
15 I'm sorry, Spencer.
16 MR. KUVIN: Let's do this.
17 MR. GOLDBERGER: Okay.
18 MR. KUVIN: Let's do this: I'll agree that
19 I'll show you how I think
it's relevant, but let me
20 go ahead and continue with
the deposition and I'll
21 ask, I guess, what you would
consider more
22 non-sexual questions, eve
n tho ugh this is a sexual
23 lawsuit, because I don't wan
t to waste everyone's
24 time for showing up here tod
ay. So let me -- let
25 me ask some basic questions
and then I'll determine
(561) 832-7500 PROSE COURT REPORTING AGENCY,
INC. (561) 832-7506
Electronically signod by Joana RIcclutl
(601-280-428-9381)
Electronically signed by Jeana Ricc
iuti (601.280-42841381)
4silfertrbehoo..44... e•aadt manna
••m. •
EFTA00726546
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO. 502008CA037319XXXXMB AB
Plaintiff,
v.
and
Defendants.
AFFIDAVIT OF JACK A. GOLDBERGER, ESQ.
STATE OF FLORIDA ) SS
COUNTY OF PALM BEACH )
BEFORE ME, the undersigned authority, personally appeared Jack A.
Goldberger, Esq. having personal knowledge and being duly sworn, deposes and
says:
1. I am co-counsel for Defendant, Jeffrey Epstein, in this and other
pending matters involving Mr. Epstein.
2. I am becoming increasingly concerned about my client's ability to
receive a fair trial with the recent press coverage of these cases.
3. Mr. Kuvin specifically told me prior to a hearing at the Palm Beach
County Courthouse concerning Mr. Epstein that:
a) He knew that he did not expect to make much money in this
case.
CT
Page - 1 -
EFTA00726547
b) He was a young lawyer, he knew he needed to market
himself and get as much publicity for himself and his firm as
possible.
c) He pointed out that his firm has an advertising plan to market
to other lawyers;
d) The Epstein case was another marketing method for himself
and his firm.
4. In particular, Mr. Kuvin had to have given a copy of Mr. Epstein's
video deposition to The Palm Beach Post in this matter and the abbreviated
deposition ended up on the internet.
5. The decision to terminate/adjourn the deposition and seek relief
from the court was made by the attorneys, Michael Pike and me, not Mr. Epstein.
Mr. Epstein followed our legal advice.
6. As the Court knows, Defendant and his attorneys must defend
against an "anonymous" Plaintiff, yet the Plaintiffs attorneys including Mr. Kuvin,
apparently intend to fry this case in the press to prejudice Mr. Epstein's right to a
fair trial.
FURTHER THE AFFIANT SAYETH NAUGHT.
/ Jack A. Goldberger, Esq.
I
Page - 2 -
EFTA00726548
STATE OF FLORIDA
COUNTY OF PALM BEACH
I hereby Certify that on this day, before me, an officer duly authorized to
administer oaths and take acknowledgments, personally appeared
Jack A. Goldberger, Esquire, known to me to be the person described in and who
executed the foregoing Affidavit, who acknowledged before me that he executed
the same, that I"lied upon tD,e following form of identification of the above
named person: 4tie 01201--nZ, and that an oath was/was not
taken. "-
WITNESS myhand and official seal in the County and State last aforesaid
this 1 P
- 7 day of 220444.G at--( , 2009.
INT NAME: 56/e9 el'i&6 2.c
JESSICA CADSSELL I NOTARY PUBLIC/STATE OF FLORIDA
!NCO/MISSION D0853529 COMMISSION 653569
EXPIRES: Awn It 2013
K•1 Bas5xl Um Scary PoitPc Undenters MY COMMISSION EXPIRES: 04'-/?-,/ 3
Page - 3 -
EFTA00726549
Page 1 of 2
D. Critton Jr. ktrtAil
From: Martin Weinberg
Sent: Friday, September 18, 2009 7:07 PM
To: Epstein, Jeffrey
Cc: D. Critton Jr.
The newest - identifies the station's source
Epstein Plea Bargain Unsealed
Comments 0 I Recommend 0
September 18, 2009 6:11 PM
Al Pefley
By all accounts, it was a sweet deal that Palm Beach billionaire Jeffrey Epstein struck with the feds.
One that most of us probably wouldn't have gotten.
He pleaded guilty to engaging in sex with teenage girls and got very little time in the county jail. Not
even prison.
Epstein's lawyers kept the details of the deal sealed until today.
We just got our hands on the 11 page plea deal that Jeffrey Epstein reached with federal prosecutors in
2007.
An attorney for some of the teenage girls who were Epstein's victims calls this plea deal "atrocious" and
he says "it's an embarrassment to the U.S. Attorney's office." Billionaire Jeffrey Epstein could've gone to
prison for life.
Instead, he got just 18 months.
Police say he had teenage girls coming to his Palm Beach home to give him massages and also perform
sex acts on him.
One attorney for some of the girls says Epstein victimized at least 33 teenage girls.
tl 11
9/22/2009
EFTA00726550
Page 2 of 2
"He could've faced at least 33 life sentences had he been convicted under these charges," said Spencer
Kuvin, with the law firm Leopold-Kuvin in Palm Beach Gardens.
But instead, Epstein spent little time behind bars under a secret plea deal with federal prosecutors.
"It's extremely unfair, extremely unfair to the 33 girls because it essentially brushes them aside as
though nothing happened to them and it wasn't a big deal," Kuvin said.
The secret plea bargain has just been made public and it reveals Epstein agreed to pay for an attorney to
represent all the victims who came to his home for sex acts.
In addition, if any of the girls decides to him for damages, Epstein gave up his right to contest the
amount of money they could collect up to 50-thousand dollars.
Also, the plea deal specifies if Epstein successfully meets the house arrest an milli deal,
the government won't charge four women in the case, including his girlfriend , N ho
brought the teenage girls to him.
"There is no other person, no other person who would've gotten such a sweetheart deal had they not
been as wealthy and as powerful as Jeffrey Epstein," Kuvin said.
The U.S. Attorney's office in Miami declined to comment on the plea deal.
In a written statement, Epstein's defense attorney says: "He is looking forward to putting this difficult
period of his life behind him."
Martin G. Weinberg, Esq.
20 Park Plaza, Suite 1000
Boston, MA 02116
617-227-3700
===...===
This Electronic Message contains
information from the Law Office of
Martin G. Weinberg, P.C.,
and may be privileged. The
information is intended for the
use of the addressee only. If you
are not the addressee, please note
that any disclosure, copying,
distribution, or use of the
contents of this message is
prohibited.
9/22/2009
EFTA00726551
• The palm Beach Ibst
MIDAY,
SEPTEMBER 4, 2r 9
PalenBeachPost,com
0 BUSINESS
CA
Appeals court backs unsealing
of Epstein's '07 deal with fells
By SUSAN SPENCER-WENDEL ey manager of billionaires •
Pals Reach Poil Staff Writer have fought ;vigorously
WEST PALM BEACH - against the agreementh
An appeals court has release.. They have 15
affirmed a lower court days to request a rehear-
ruling unsealing 'the con- big with the 4th District
fidential deal Jeff* Ep- Court of Appe.al. • •
stein struck with federal Absent that, it will be- Epstein
prosecutors to avoid being come public. Attorneys
charged by them. Epstein's local criminal for the
Palm Beach
TLe 4th District Court defense attorney Jack
money
of Appeal this week up- Goldberger did not return manager ' •
held Circuit Judge Jeffrey a call seeking comment have 15
Colbath's earlier decision Epateinit ovm attorneys, days to seek
to unseal the agreement' in federal filings, have a rehearing.
Attorneys for the.mon- See EPSTEIN, 68 I.
s to Marines, including grandson, 2B is Officials seek public's suggi
EFTA00726552
.• •
•• t• C.:I •.•'.
'twat]
•
deposition
cPSTEilsifrapi.48.
• tzi .i • 3. An attorney's questioning
i,313.;713d 'to. 63 :eonft$1C.•
of Epstein becomes personal.
•
SI deferred proseetb
agreement with the .S.
Attcp-ney% .• .
. in ft•s
:, !her 200Z sis."un- •
wphT:
..S. enter and .1higiil'ir. Donald limp And Prince who represents an alleged
tineeuel-" Andrew ••"International victim identified only as
• Attorneys. foi- The Palm. MOneymaii of Mystery," "BR", Kuvin questioned
Beach Post as well as al- declared a 2002 New York Epstein about the shape
leged victims of Epstein's ne' profile of Er of. hia genitalia and the
Sexual advances,sought to siht ma • • deposition abruptly ended,
have the deal unsealed in fla pleaded guilty in according to a transcript
state court tr. 2008 to procuring teens .Kuvin has Since made
Colbath found, that,the for' prostitution and was. a motion in court to be
sentenced to' 18 months able to inspect Epstein%
Fffer:Ot been fPl ollpote b; in jail; but allowed but exH genitalia ' .
ect re
'• an earlier judge. tensively for work release. Kuvin Said Thursday he
"There is nothinmore Epstein • was released' in seeks to corroborates de-
fimdamentally •im t late July after serving is scriptiqn one woman gave
than for the. pu and months. of the sentence. • • Palm Beach police. -
press to observe the He now faces civil Because Epstein is in-
q vernment is doigg. its lawsuits filed by young voking his right to remain
" Post attorney. women allegedly lured to silent in depositions, this •
, Shullman has said:"there his Palm Beach home and is the only way to do it,
is . great public interest paid to pet tot ut massages Kuvin
• in how.• everybody. in this and other acts. • . • • "We want to corroborate
case is doing their job." That' civil litigation is what •those girls' saw,"
• According to farious intensifyink. Kuvin said. . •
media accounts, Epstein This Week, while Ep-
movedzauseigeleLtbat. in- stein was being s-usan_spencer_weridel0
cluded President Clinton, by attorney Spencer vin, pbpostcom
,eniw Atiw neq0 It
•
" r'1"1.,,-;•2-;• 0 4.431;Werr • -
EFTA00726553
Jeffrey Epstein victim seeks to P :al document from sex offender case Page 1 of 2
a a,?=a,
as
NNW .iw-sHjtorrt
seem Newsletter Center I Log Ln
CMOS
ntitia4cOnlicagaketil Tseseiry• Duty U. reel
eat fa web Et =1
NOWA I MEWS I SOCIETY I DUENESS ARTS I FASHION I Minimisers OPINION I j
UFEtirn.ES LStull SOOTS I ADVERTISE
correcrus I
ICIWWWWW•
mig•hiwtatuziya • Electronic Edition Now Available!
alsiweicaftmgenito; Click Here To Subcribe
NEWS
itthq%00 I AftiliVel
k n
E.maR this page Go Print the page * Most popular
Jeffrey Epstein victim seeks to unseal document from sex offender case
Gieceicii Wave
News, fronds & tips
Click-2-Listen for environmentally
Sy seCh'EcE DARGAN. Deily tat Stag Wraw friendly living...;,
Monday. July 13, 2009
One of the young women victimized by Jeffrey Epstein is asking that a federal non.prosecution agreement
pertaining to the sex offender be unsealed to help 0 the discovery process cl her chit case.
She also says Val a federal judge's riding alowing victims and veer attorneys to view the document does not
pertain to her because her case is Bed in state court
Attorneys Spencer Kutch arC Diana Marlin filed court papers Monday on belt"... asking that the
Fourth DistrictCourt Of Appeal uphold a state judge's ruling to unseal the deal ircuit Judge Jeffrey
Colbeth ruled the document was mproperty sealed at the limo of Epstein'• plea hearing. where he pleaded
gully to soliciting prosfdution and soliciting a minor for prostitution.
Kuvnikfgigs respcase says, is entitled to this document as both astir of Epstein and as a citizen of
M_ needs the agnumemllo demonstrate Epstein lacks a valid basis toed the Efts Amendment
dining the discovery phase of her civil case. And, as a Florida Olden, K b right and interest to
review the non-prosecution agreement.'
There are more than a dozen ova Ultimata — both state and federal — perking aninstEpsteit, 56. All
Woken skier allegations: Epstein. through Pia employees and assistents. brought minor gilt to his Palm
Beach home on El Salo VVey for erotic massages and sometimes sex
attorneys flied papers with the appetite own. asking to throe out Colbath's
Epstein's attorneys say he wil suffer -rreparaltle harm once the documents are produced'
Ep0ein's attorneys say the document cannot be made public because it references grand jury pmceragra
which are protected under Federal Rule of Clinical Procedure.
i3..,: anal
.'s attorneys say Epstein faded lo raise this argument in his motion to make the agreement
and, in addition, the Rite Orly pertains if disciosure would "reveal secret Inner vnxkings of the
grand jury' Epstein has not demonstrated that to be the case, the court papers say.
Epstein's attorneys argue that a federal judge already has denied a (notion to unseal the document and that
victims and thee attorneys way view the document but may not endow Its contents to other parties
Kirat, whose dent fled sue in state court, says that ho and his crient would have to go back to federal court
and go through a rigorous process to view the document
'My client a not bound by the federal cast ruling? Kuvin said by phone. 'She sliouldn1 have to subject
herseff to federal jurisdiction for a document that should be putec anyway. She's a *tea victim and she has
never seen it and I have never seen it.'
Attorney. Edwards, represeneng and attorney Deanna *name" representing the Palm Beach
Post are expected to have hied owl papers asking to uphold the ring to unseal Edwards and Shamenn
did rot retnn cats on Monday.
Epstein we be released (torn the Palm Beach County Stockade July 22. after sensing less than 13 months of
his 18-month sentence.
Talk of the Town
We appreciate reader comments on the story. but at PalmEteschDadyNewa.comt we want to avoid
comments that are obscene, hateful, racist or otherwise inappropriate. If you post such comments. we wit
delete them. If you see such comments, pleas* report them to us by °mating
feedbacktDptcladynews.00m.
Joyce Retook,
((E .-- .1,
httn://www.valmbeachdailvnews.com/news/content/neves/2009/07/13/webepstein071309.h... 7/14/2009
EFTA00726554
•••
Court: Epstein
agreement
stays sealed
By WILLIAM KELLY
Daily News Staff Writer
has
The Fourth District Court of Appeal
reques t to halt
agreed to Jeffrey Epstein's -prosecu-
the impending release of his non govern-
tion agreement with the federa l
ment.
Circuit Judge Jeffrey Colbath had or-
noon
dered the release of the documents at state
were sealed in
today. The documents convict-
court last year when Epstein, a
ed sex offender and billionaire financier,
charge s. Col-
pleaded guilty to two felony
ures weren 't fol-
brath ruled proper proced
lowed in sealing the docum ents.
them
Now the decision whether to make
Please see EPSTEIN, Page A4
Copyright 2009
A4 Palm Beach Daily News, Thursday, July 2 ti
Palm Beach Daily News 4
Va. 113, No.257
2 Sections
•
EPSTEIN
Lawyer Document release would harm client
yet for The Palm Beach Post, izen, and not a billionaire,
From Page Al have argued that the public this document would have
public is in the hands of the and media should have ac- been made public a long
appellate court, which has cess to the information and time ago.'
given attorneys on both that the victims should be Epstein pleaded guilty
sides of the case a total of able to use it in their law- to solicit ation of prostitu-
20 days to present their ar- suits. tion and procuring teenag-
guments. Kreusler-Walsh would ers for prostitution. He was
Epstein's appell ate law- not comment on the Fourth sentenced to 18 months in-
yer, Jane Kreusl er-Wa lsh, Distri ct's order. carceration, but is due to
made an emergency re- But Spencer Kuvin, a get out five months early,
quest Wednesday that the lawyer for one of the vic- on July 22.
appellate court annul the tims, called the decision State and federal au-
lower court order, saying "frustrating." thorities said Epstein paid
release of the agreement "The rules shouldn't teenage girls for massages
would cause irreparable be different for rich peo- and sometimes sex at his
harm to her client. ple than they are for poor Palm Beach home.
Attorneys for women people," Kuvin said. 'Had — wkelly
suing Epstein, and a law- Epstein been a regular cit- glphdatlynews.com
1(
EFTA00726555
Girl sues Epstein, two others
she says conspired in massages
Jane Doe,' 1Z sues in state court !these two conspired with
hint to help with the criminal
Oter dropping afederal suit enterprise," Leopold.said.
Jane Doe, through her
father and stepmother: filed
.
a federal lawsuit against
By LARRY KELLER
MtnBeath Post Ste Writer Epstein in January. She dis-
WEST PALM BEACH - A former Palm misse d it after her mother
Beach Community College student who .said she wasn't consulted
police say procured underage girls to give Epstein about the litigation and
Jeffrey Epstein sexual massages at his Palm mother is actingsought to intervene. The
Beach mansion, and EpsteinS personal assis- the latest lawsui on her daughter's behalf in
tant have been sued along with Epstein over t.
Epsteinb lawyer has defiled the gide al-
their alleged conduct. legations, and said her family is simply at-
The girl behind the lawsuit was 14 years tempting to get money from a very rich man.
old when she contends he engaged in sexual E in, 55, is a Manhattan money manager
conduct with her after she went to his water wlw has homes there,
front home in 2005 to give him a massage. Virgin Island in New Mexico and the
Her lawsuit, filed under the name Jane Doe, Palm newt mansi s, in addition to his $8.5 million
seeks unspecified damages from Epstein for on.
TWo other Jane Does have sued Epstein
sexual assault and intentional infliction of in federal court
emotional distress. this year, making is'milar al-
• legations to those of the first Jane Doe. Those
She also sued cases remain active.
Loxahatchee and ew cork
of Also pending against Epstein in state court
City on grounds o conspiracy and civil rack- is a felony change of solicitation of prostitu-
eteering. tion arising from the same alleged incidents
"We want a full measure of justice for with several girls. That case is
aid her attorney, Ted Leopold. set for trial iii
July, two years after he was indicted..
who attended Palm Beach Com- Jane Does new lawsui filed in Patin Beach
mum lege, was paid by Epstein to bring County Circuit Cour, ist,the
girls to his mansion for massages and more, detailint.Epsteinb most explicit in
according to Palm Beach police. "Pm like a the only suit to includ al and
'Heidi Fleiss," they said she told them. Her as defend e and
attorney could not be reached immediately spiracy and racket ants, and the one make con-
for t. eering allega tions.
Jane Doe will turn 18 in May. She lives with
was an Epstein personal assistant other family memb
who arranged the encounters, even escort- is nearing gradua ers in Palm Beach County,
ing the girls to his massage room, police working part.ti tion from high school and is
alleged. me, Leopold said.
0 larry_keliornithrost.com
EFTA00726556
EFTA00726557
THE SHINY SHLL Vro' LiRSDAY , I li 0
No monitoring device for Epstein
'Difficult part in his life is ending,' says attorney for sex out of jail on work release for 16 hours The plea agreement stipulated that
a day, six days a week since October,
offender released from jail. Victims say sentence too short. has been going to his Palm Beach
Epstein, a billionaire financier, would
not be placed on electronic monitor-
home as well as his West Palm Beach ing, Goldberger said. An earlier court
office for the past two weeks. order incorrectly had him listed as
By MICHELE DARGAN cording to a court order. His attorney Jack Goldberger, as having to be monitored.
Daily News Staff Wilier Epstein, who served less than 13 well as Palm Beach County Sheriffs "A very difficult part in his life is
months of his 18-month sentence at Office records confirm that Epstein ending, and he is looking forward to
Convicted sex offender Jeffrey Ep- the Palm Beach County Stockade, has been to his home on several occa-
stein, released from jail shortly after 6 moving on," Goldberger said.
will serve one year of probation at his sions. Goldberger said Epstein was giv- Epstein, 56, pleaded guilty to pro-
Epstein a.m. Wednesday, will not be tracked El Brillo Way home. He already has en PESO permission to be at home for curing a minor for prostitution and so-
Served less than by an electronic monitoring device registered as a sex offender. specific time periods in order to make
13 months. during his one-year probation, ac- In addition, Epstein, who has been the transition from Jail to his home. Please see EPSTEIN, Page A6
EFTA00726558
and has a young daughter, whoth
EPSTEIN she wants to protect. PROBATION
Civil lawsuits pending 'It's really upsetting to me,"
she said. "I'm scared. He's such a cQNDETIONS
From Page Al powerful man, and I don't know
what he's capable of. I would have Conditions of Jeffrey Epstein's
itching prostitution. liked to see him get a longer jail one-year probation:
More than a dozen young term. He just got a slap on the wrist • Must register as a sex offender.
women, who were minors at the and what he has done to all of us is • Will not be electronically
time of their encounters, are suing never going to leave us." monitored.
Epstein for sexual abuse. Among She said that she gets upset • Shall have no unsupervised
them: Jane Doe No. 3 and Jane Doe when she hears people accuse conduct with minors, and the
Na 5, who both say they fear Ep- the victims of being all about the supervising adult must be
stein and believe he should have money. approved by the Department of
gotten a much harsher sentence. "Ws about getting justice,' she Corrections.
Both women have filed federal said. 'He's acting like he's the vic- • Shall submit to a mandatory
lawsuits. tim and he walks away. I couldn't curfew from 10 p.m. to 6 a.m.
Doe No. 3, who was 16 at the talk about it for a long time. I have • Shall not live within 1,000
time of her encounter with Ep- flashbacks. I thought it was all my Palm Beach Post Photo by Lannis Waters feet of a school, day care center,
stein, said she was shocked to fault for a long time and that's the park, playground or other
Jeffrey Epstein is whisked away from the Palm Beach County Jail shortly place where children regularly
learn Sunday that the Palm Beach wayhe wanted me to feel: after 6 a.m. Wednesday. Epstein left the jail through the sally port, where
resident was getting out of jail Miami attorneys Adam congregate.
prisoners are brought In, rather than through the main doors where or Shall not have any contact with
early. She said she also didn't find Horowitz and Stuart Mermelstein
out he was on work release until represent Jane Does No.2 through prisoners are routinely released. the victims threat," or indirectly,
months after the fact. No. 8 in federal lawsuits. confidentiality agreement. But he ' ii ate court, representing victim induding through a third person.
'I'm afraid of seeing him'
"I'm scared to go to Palm
'We're outraged that a regis-
tered sex offender has such a short
sentence? Horowitz said. "They
did say that she didn't want to be
in the public eye anymore.
"She was not happy with the
i Kuvin said his client is "petri-
fied'' about Epstein's release.
"A man with unlimited wealth
la Shall not view, own or posses
obscene, pornographic or
sexually stimulating visual or •
auditory material.
•
I Beach because I'm afraid of see- put people in jail for longer periods resolution; Kuvin said, "but she can hire people to follow her, dig
I ing him out in public? said Doe of time for much lesser offenses. wanted it over. He's got investiga- into every crevice of her personal • Shall not work or volunteer in
No. 3, no
DataSet-9
Unknown
1 pages
From: Jeevacation
To: Jean Luc
Subject: Fwd: C.L. v. Epstein - Notice of Deposition of in Miami
Date: Wed, 21 Apr 2010 21:15:09 +0000
Attachments: bcic; 20100421170546152.pdf
Sent from my iPhone
Begin forwarded message:
From: "Connie Zaguirre, CP, FRP"
Date: April 21, 2010 5:17:22 PM EDT
To: <1 >, "Darren Indyke"
Subject: C.L. v. Epstein - Notice of Deposition of in Miami
Enclosed please find Plaintiff's Notice of Deposition of on 5/18/10 in
Miami.
Connie Zaguirre, CP, FRP - Assistant for Robert D. Critton, Jr.
303 Banyan Boulevard I Suite 400 I West Palm Beach I FL 33401
Phone: I Fax:
I w.vw bdclaw com
This e-mail contains legally privileged and confidential information intended only for the individual or entity
named within the message. Should the intended recipient forward this message to another person or party, that
action could constitute a waiver of the attorney/client privilege. If the reader of this message is not the intended
recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review,
dissemination, distribution or copying of this communication is prohibited. If this communications was
received in error, please notify us by reply e-mail and delete the original message.
EFTA00890952
DataSet-9
Unknown
33 pages
- Not an Official Document Page 35 of 67
!Filing Date: ]111-JAN-2011
Filing Party:
Disposition Amount:
ON DEFENDANT EDWARDS' MOTION FOR SUMMARY
Docket Text:
JUDGMENT DCROW
198 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 13-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: DEAN KRETSCHMAR
199 MOT - MOTION
Filing Date: 114-JAN-2011
Filing Party: [EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: FOR RECONSIDERATION
200 MOT - MOTION
Filing Date: 18-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: FOR ORDER TO TAKE SCOTT ROTHSTEIN'S DEPOSITIONA
201 I MOT - MOTION
Filing Date: 20-JAN-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: FOR ORDER TO TAKE SCOTT ROTHSTEIN'S DEPOSITION
202 NOH - NOTICE OF HEARING
Filing Date: 20-JAN-2011
Filing Party: IACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 1/27/2011
203 MOT - MOTION
Filing Date: 21-JAN-2011
Filing Party: EDWARDS, BRADLEY J
http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_cpy_doct.cp_dIctrpt_docket_report.. 11/29/2011
EFTA01087218
- Not an Official Document Page 36 of 67
'Disposition Amount:
Docket Text: TO EXPAND INTERROGATORIES
204 NCAN - NOTICE OF CANCELLATION
,,--
Filing Date: 21-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: OF DEPO OF RUSSELL ADLER
205 NCAN - NOTICE OF CANCELLATION
Filing Date: 21-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: OF DEPO OF HERB STETTIN
206 NCAN - NOTICE OF CANCELLATION
Filing Date: 24-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: DEPO OF KEN JENNE
207 MOT - MOTION
Filing Date: 24-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: OF RUSSELL ADLER-FOR PROTECTIVE ORDER
208 NOH - NOTICE OF HEARING
Filing Date: 24-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: [JAN 26 2011
210 SRSV - SUBPOENA RETURNED /
SERVED
Filing Date: 24-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: 'none.
209 I ORD - ORDER
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlorpt_docket_report . 11/29/2011
EFTA01087219
- Not an Official Document Page 37 of 67
Filing Date: [25-JAN-2011
Filing Party:
Disposition Amount:
r
DENYING DEFENDANT EDWARDS' MOTION FOR
Docket Text:
RECONSIDERATION
211 NCAN - NOTICE OF CANCELLATION
Filing Date: 25-JAN-2011
Filing Party: ADLER , ESQ, RUSSELL S
Disposition Amount:
Docket Text: none.
212 SRSV - SUBPOENA RETURNED /
SERVED
Filing Date: 25-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: [none.
213 NCAN - NOTICE OF CANCELLATION
[Filing Date: 1126-JAN-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: OF DEPOSITION
1214 NCAN - NOTICE OF CANCELLATION
Filing Date: 26-JAN-2011
Filing Party: IACKERMAN , ESQ, JOSEPH L
Disposition Amount:
—,„
Docket Text: OF DEPOSITION
215 NOH - NOTICE OF HEARING
Filing Date: 27-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: FEBRUARY 8, 2011
216 J MOT - MOTION
Filing Date: 28-JAN-2011
Filing Party: EDWARDS, BRADLEY J
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlarpt_docket_report... 11/29/2011
EFTA01087220
- Not an Official Document Page 38 of 67
Disposition Amount:
Docket Text: FOR A STAY OF SUBPOENA
217 NOH - NOTICE OF HEARING
Filing Date: 28-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: FEBRUARY 1,2011
218 MOT - MOTION
Filing Date: 28-JAN-2011
Filing Party: ,EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: ITO
DETERMINE STATUS
219 NOH - NOTICE OF HEARING
Filing Date: 28-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: MARCH 30,2011
220 I NOH - NOTICE OF HEARING
Filing Date: 28-JAN-2011
Filing Party:
Disposition Amount:
Docket Text: MARCH 30,2011
221 I NCAN - NOTICE OF CANCELLATION
Filing Date: 31-JAN-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: OF DEPOSITION
222 NCAN - NOTICE OF CANCELLATION
IFiling Date: 31-JAN-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: OF DEPOSITION
223 ORD - ORDER
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11/29/2011
EFTA01087221
- Not an Official Document Page 39 of 67
Filing Date: 01-FEB-2011
Filing Party:
Disposition Amount:
ON DEFT EDWARDS' MOTION TO STAY SUBPOENA, ETC. D
Docket Text:
CROW
224 RNOH - RE-NOTICE OF HEARING
Filing Date: 01-FEB-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: SPECIAL SET 3/31/2011
225 MOT - MOTION
Filing Date: 03-FEB-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO DETERMINE IF REHEARING IS APPROPRIATE
226 RNOH - RE-NOTICE OF HEARING
Filing Date: 03-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 2/15/2011
227 I NOH - NOTICE OF HEARING
Filing Date: 03-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 2/8/2011
228 NOF - NOTICE OF FILING
Filing Date: 04-FEB-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: PAGE AND LINE DESIGNATIONS
229 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 07-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doctcp_dktrpt_docket_report... 11/29/2011
EFTA01087222
- Not an Official Document Page 40 of 67
Disposition Amount:
Docket Text: none.
230 MOT - MOTION
Filing Date:
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO
OVERRULE OBJECTIONS AND COMPEL DEFT EDWARDS TO
Docket Text:
ANSWER QUESTIONS AND APPEAR FOR FURTHER
1231 1 NOH - NOTICE OF HEARING
Filing Date: 08-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 4/1/2011
232 MCMP - MOTION TO COMPEL
Filing Date: 08-FEB-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: /MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED
1233 1NOH - NOTICE OF HEARING
Filing Date: 08-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 4/5/2011
234 ORD - ORDER
Filing Date: 08-FEB-2011
Filing Party:
Disposition Amount:
ON PLAINTIFF'S MOTION TO DETERMINE IF REHEARING IS
Docket Text:
APPROPRIATE IS GRANTED. D CROW
235 - I NOH - NOTICE OF HEARING
Filing Date: 11-FEB-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_cliMpt_docket_report... 11/29/2011
EFTA01087223
- Not an Official Document Page 41 of 67
Docket Text: 112/17/2011
236 MCMP - MOTION TO COMPEL
Filing Date: 11-FEB-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
237 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 11-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
238 NCAN - NOTICE OF CANCELLATION
Filing Date: 11-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: [OF HEARING ON 2/15/11
239 MOT - MOTION
Filing Date: 14-FEB-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO CONTINUE JURY TRIAL
240 NOH - NOTICE OF HEARING
Filing Date: 14-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 2/16/2011
241 JAGOR - AGREED ORDER
Filing Date: 15-FEB-2011
Filing Party:
Disposition Amount:
Docket Text: GRANTING PLTFS MOTION TO AMEND COMPLAINT. D CROW
261 MFPO - MOTION FOR PROTECTIVE
ORDER
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_gry_doct.cp_dktrpt_docket_report. . 11/29/2011
EFTA01087224
- Not an Official Document Page 42 of 67
Filing Date: I15-FEB-2011
Filing Party:
Disposition Amount:
Docket Text: ELIZABETH KIM
262 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 15-FEB-2011
Filing Party:
Disposition Amount:
Docket Text: ICHRISTINAFITCH
242 CNS - CONSENT
16-FEB-2011
EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO MOTION TO CONTINUE JURY TRIAL
243 NOTD - NOTICE OF TAKING
DEPOSITION
Flung Date: 17-FEB-2011
Filing Party:
Disposition Amount:
Docket Text: none.
244 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 17-FEB-2011
Filing Party:
Disposition Amount:
Docket Text: none.
245 ORD - ORDER
Filing Date: 17-FEB-2011
Filing Party:
Disposition Amount:
ON DEFT EDWARDS' MOTION TO COMPEL IS GRANTED. D
Docket Text: CROW
246 I ORD - ORDER
Filing Date: 17-FEB-2011
i
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket report... 11/29/2011
EFTA01087225
- Not an Official Document Page 43 of 67
Filing Party:
Disposition Amount:
GRANTING PLAINTIFF'S MOTION TO CONTINUE TRIAL AND
Docket Text:
SCHEDULING CASE MGMT CONFERENCE. D CROW
249 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 25-FEB-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
OBJECTIONS TO CANCELLED NOTICE OF DEPOSITION DUCES
TECUM OF RECORDS CUSTODIAN OF TRUSTEE HERBERT
Docket Text:
STETTIN JANUARY 20, 2011, AND MOTION FOR APPOINTMENT
OF ROBERT CARNEY AS SPECIAL MASTER
247 NOH - NOTICE OF HEARING
Filing Date: 28-FEB-2011
Filing Party:
Disposition Amount:
Docket Text: SET FOR 02-MAR-11
248 MOT - MOTION
Filing Date: 28-FEB-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO APPOINT COMMISSIONER TO TAKE DEPO
250 RESP - RESPONSE TO:
Filing Date: 28-FEB-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: PLAINTIFF'S AMENDED COMPLAINT
251 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 28-FEB-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
252 RNTD - RE-NOTICE OF TAKING
DEPOSITION
htqx//courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_publicAry_doct.cp_dIctrpt_docket_report... 11/29/2011
EFTA01087226
- Not an Official Document Page 44 of 67
Filing Date: P8-FEB-2011
Filing Party: ACKERMANESQ,JOSEPHL
Disposition Amount:
Docket Text: none.
253 EAGOR- AGREEDORDER
Filing Date: 02-MAR-2011
Filing Party:
Disposition Amount:
'ICOMMISSION
ONPLTJEFFREYIN EPSTEIN'
NEW YORK SISRENEWED
MOTION
GRANTED.
D TO**2APPOINT
CROW CC' S
Docket Text:
IMLDTOJOSEPHL. ACERKMANJRESQ.
254 SRNS-
SERVEDSUBPOENA RETURNED / NOT
Filing Date: I 02-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: none.
255 NOTD- NOTICEOFTAKING
DEPOSITION
Filing Date: 08-MAR-2011
Filing Party: ACKERMAN, ESQ,JOSEPHL
Disposition Amount:
Docket Text: none.
256 SRNS-
SERVEDSUBPOENA RETURNED
/ NOT
Filing Date: H 09-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: none.
257 RNTD- RE-NOTICEOFTAKING
DEPOSITION
Filing Date: 10-MAR-2011
Filing Party: ACKERMAN, ESQ,JOSEPHL
Disposition Amount:
IDocket Text: none.
http://courtcon.co.palm-beach.fl.us/pis/jiwp/ck_public_qry_doct.cp_didrpt_docket report.. 11/29/2011
EFTA01087227
- Not an Official Document Page 45 of 67
1258 III±IOH - NOTICE OF HEARING
Filing Date: 11-MAR-2011
Filing Party: —ISCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: 3/30/2011
259 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 11-MAR-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
RCPT RECEIPT FOR PAYMENT
Filing Date: 14-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: A Payment of -$100.00 was made on receipt CAMB534930.
OPRHV - FEE/PRO HAC VICE
($100.00)
Filing Date: 14-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: none.
260 MOT - MOTION
Filing Date: 14-MAR-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE
263 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 16-MAR-2011
Filing Party: - 03
Disposition Amount:
Docket Text: FOR HERBERT STETTIN, TRUSTEE
264 NOH - NOTICE OF HEARING
Imo -
http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry doct.cp_dktrpt docket_report... 11/29/2011
EFTA01087228
- Not an Official Document Page 46 of 67
Filing Date: b16-MAR -2011
Filing Party:
Disposition Amount:
Docket Text: 3/28/2011
265 NCAN - NOTICE OF CANCELLATION
Filing Date: I17-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: OF DEPO
7RSV - SUBPOENA RETURNED /
266 I
Filing Date:
SERVED
18-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: none.
267 NOAP - NOTICE OF APPEARANCE
Filing Date: 18-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: LIMITED - SPENCER T KUVIN ESQ
268 NOH - NOTICE OF HEARING
Filing Date: 22-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: MARCH 28 2011
269 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: ]23-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: CARL H. LINDER
270 I NOH - NOTICE OF HEARING
Filing Date: 23-MAR-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
http://courtcon.co.palm-beach.fl.us/p1s/jiwpick_public_qry_doctcp_dIctrpt_docket_report... 11/29/2011
EFTA01087229
- Not an Official Document Page 47 of 67
'Disposition Amount:_
Docket Text: 3/28/2011
271 MOT - MOTION
Filing Date: 24-MAR-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
FOR PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL
Docket Text:
AND DFT/COUNTER PLT FROM MAKING STATEMENTS...
272 ll NOH - NOTICE OF HEARING
Filing Date: 24-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: SET FOR 08=APR-11
273 NOT - NOTICE
Filing Date: 25-MAR-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
274 RPT -. REPORT
Filing Date: 29-MAR-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: CASE MANAGEMENT REPORT
275 ORD - ORDER
Filing Date: 30-MAR-2011
Filing Party:
Disposition Amount:
ON NOTICE OF LIMITED APPEARANCE TO FILE MOTION FOR
Docket Text: PROTECTIVE ORDER AND OBJECTION TO SUBPOENA FOR
JOINT PRIVILEGE DOCUMENTS. SEE ORDER. D CROW
276 AGOR - AGREED ORDER
Filing Date: 30-MAR-2011
Filing Party:
Disposition Amount:
'MOTION FOR PROTECTIVE ORDER IS GRANTED IN PART AND
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_cry_doct.cp_dktrpt_docket_report... 11/29/2011
EFTA01087230
- Not an Official Document Page 48 of 67
'Docket Text: "DENIED IN PART. D CROW
277 NCAN - NOTICE OF CANCELLATION
Filing Date: 31-MAR-2011
Filing Party:
Disposition Amount:
Docket Text: OF RE-NOTICE OF TAKING DEPO DUCES TECUM
278 MOT - MOTION
Filing Date: 01-APR-2011
Filing Party:
Disposition Amount:
Docket Text: FOR PROTECTIVE ORDER AND STAY OF ORDER
279 NOTD - NOTICE OF TAKING
DEPOSITION
04-APR-2011
SCAROLA , ESQ, JACK
Docket Text: none.
280 MOT - MOTION
Filing Date: 05-APR-2011
Filing Party EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: TO PERMIT ADDITIONAL INTERROGATORY
281 NOFI - NOTICE OF FILING
INTERROGS
Filing Date: _I 05-APR-2011
Filing Party: I EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
282 RESP - RESPONSE TO:
Filing Date: 05-APR-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
IN OPPOSITION TO EPSTEIN'S MOTION FOR PROTECTIVE
Docket Text: ORDER TO PRECLUDE EXTRA-JUDICIAL STATEMENTS AND
COMMENTARY TO THE MEDIA
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlarpt docket_report... 11/29/2011
EFTA01087231
- Not an Official Document Page 49 of 67
283 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 07-APR-2011
Filing Party: jACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
284 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 07-APR-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
285 NOH - NOTICE OF HEARING
Filing Date: 07-APR-2011
Filing Party:
Disposition Amount:
Docket Text: ON 4/20/11
286 1EXT - MOTION FOR EXTENSION OF
TIME
Filing Date: 08-APR-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO SERVE AMENDED COMPLAINT
287 MOT - MOTION
Filing Date: 11-APR-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: FOR PROTECTIVE ORDER TO PREVENT VIDEO DEPOSITION
288 [
Filing Date:
NTD - RE-NOTICE OF TAKING
EPOSITION
11-APR-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
289 ORD - ORDER
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt docket_report... 11/29/2011
EFTA01087232
- Not an Official Document Page 50 of 67
Filing Date: 12-APR-2011
Filing Party:
Disposition Amount:
Docket Text: ON CASE MANAGEMENT STATUS ( D. CROW)
290 I REQ - REQUEST
Filing Date: 12-APR-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: FOR PRODUCTION
291 AGOR - AGREED ORDER
Filing Date: 13-APR-2011
Filing Party:
Disposition Amount:
GRANTING MARTIN G. WEINBERG'S VERIFIED MOTION FOR
Docket Text:
ADMISSION TO APPEAR PRO HAV VICE ( D. CROW)
292 I AMN - AMENDED
Filing Date: 13-APR-2011
Filing Party: EPSTEIN, JEFFREY
F
Disposition Amount:
Docket Text:
293
AMENDED COMPLAINT
RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 15-APR-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
294 I REQP - REQUEST TO PRODUCE
Filing Date: 20-APR-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
[DocketText: none.
295 MDIS - MOTION TO DISMISS
[ Filing Date: ___I 20-APR-2011
Filing Party: IIEDWARDS, BRADLEY J
http://courtcon.co.palm-beach.fl.us/pis/jivvpickpublicipy doct.cp_dktrpt_docket_report... 11/29/2011
EFTA01087233
- Not an Official Document Page 51 of 67
'Disposition Amount
Docket Text: none.
296 NOH - NOTICE OF HEARING
Filing Date: 20-APR-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: 5/19/2011
297 NOH - NOTICE OF HEARING
Filing Date: 20-APR-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 5/19/2011
298 INCAN - NOTICE OF CANCELLATION
Filing Date: 21-APR-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: OF HEARING- UMC
299 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 22-APR-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
300 MCMP - MOTION TO COMPEL
Filing Date: 26-APR-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: AND IMPOSE SANCTIONS FOR FAILURE TO APPEAR
301 NOT - NOTICE
Filing Date: 28-APR-2011
Filing Party:
Disposition Amount:
Docket Text: JOINT STATEMENT OF PENDING MOTIONS
302 NOH - NOTICE OF HEARING
http://courtcon.co.palm-beach.fl.us/pls/jiwp/ckpublicAry_doct.cp_diorpt docket report... 11/29/2011
EFTA01087234
- Not an Official Document Page 52 of 67
'Filing Date: '105-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 5/19/2011
303 1MOT - MOTION
Filing Date: 05-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
TO QUASH SUBPOENA AND FOR PROTECTIVE ORDER TO
Docket Text:
PREVENT DEPOSITION OF ALFRED SECKEL
304 MOT MOTION
Filing Date: 05-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
TO ENLARGE TIME TO RESPOND TO EDWARDS' ADDITIONAL
Docket Text: INTERR
305 I AMN - AMENDED
Filing Date: 05-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
MOTION FOR A PROTECTIVE ORDER TO PRECLUDE OPPOSING
COUNSEL AND DEFT/COUNTER-PLAINTIFF FROM MAKING
Docket Text: EXTRAJUDICIAL STATEMENTS AND COMMENTARY TO THE
MEDIA AND PRESS, WITH INCORPORATED LEGAL
AUTHORITIES
306 I SUP - SUPPLEMENT
Filing Date: 06-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: STATEMENT OF PENDING MOTIONS
307 RRTP - RESPONSE TO REQ TO
PRODUCE
Filing Date: 06-MAY-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
I
http://courtcon.co.palm-beach.fl.us/pls/jiwp/ckpublic_qry_doct.cp_dktrpt docket report... 11/29/2011
EFTA01087235
- Not an Official Document Page 53 of 67
1308 I RPRS - REPLY/RESPONSE
Filing Date: 13-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
IN OPPOSITION TO DEFT/COUNTER-PLAINTIFF BRADLEY
Docket Text:
EDWARDS' MOTION TO DISMISS THE AMENDED COMPLAINT
309 NOH - NOTICE OF HEARING
Filing Date: 13-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 5/18/2011
310 NCAN - NOTICE OF CANCELLATION
Filing Date: 16-MAY-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: OF HEARING
311 NOH - NOTICE OF HEARING
Filing Date: 16-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 15/18/2011
312 SRNS - SUBPOENA RETURNED / NOT
SERVED
Filing Date: J 17-MAY-2011
Filing Party:
Disposition Amount:
Docket Text: none.
313 SRNS - SUBPOENA RETURNED / NOT
SERVED
Filing Date: 17-MAY-2011
Filing Party:
Disposition Amount:
Docket Text: none.
314 NOF - NOTICE OF FILING
http://courtcon.co.palm-beach.fl.us/p1s/jiwpick_public_qry_doct.cp dkapt_docket_report... 11/29/2011
EFTA01087236
- Not an Official Document Page 54 of 67
Filing Date: 17-MAY-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
T OF THE TELEPHONE INTERVIEW OF
Docket Text:
315 NCAN - NOTICE OF CANCELLATION
Filing Date: I17-MAY-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: OF HEARING
316 NOFI - NOTICE OF FILING
INTERROGS
Filing Date: 18-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
317 RRTP - RESPONSE TO REQ TO
PRODUCE
Filing Date: 18-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
318 OBJ - OBJECTION
Filing Date: 18-MAY-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO INTERR OF THE DEFT EDWARDS SERVED APRIL 1, 2011
319 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 18-MAY-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
320 NCAN - NOTICE OF CANCELLATION
Filing Date: 19-MAY-2011
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket_report... 11/29/2011
EFTA01087237
- Not an Official Document Page 55 of 67
Filing Party: II
Disposition Amount:
Docket Text: DEPO FO ALFRED SECKEL 5/23/11
321 NOF - NOTICE OF FILING
Filing Date: 19-MAY-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: DECLARATION OF AL SECKEL
322 SRNS - SUBPOENA RETURNED / NOT
SERVED
Filing Date: 26-MAY-2011
Filing Party:
Disposition Amount:
Docket Text: none.
323 ORST - ORDER RESETTING
Filing Date: 27-MAY-2011
Filing Party:
Disposition Amount:
Docket Text: HEARING 7/13/2011. D CROW
324 _ OBJ - OBJECTION
Filing Date: 27-MAY-2011
Filing Party:
Disposition Amount:
Docket Text: NON-PARTY
325 NOH - NOTICE OF HEARING
m ,
Filing Date: 07-JUN-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: 116/9/2011
335 NCAN - NOTICE OF CANCELLATION
Filing Date: 07-JUN-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: OF DEPOSITION DUCES TECUM
http://courtcon.co.palm-beachil.us/pls/jiwpick_public_qry_doct.ep_dIctrpt_docket_report... 11/29/2011
EFTA01087238
- Not an Official Document Page 56 of 67
1326 I RNOH - RE-NOTICE OF HEARING
Filing Date: [08-JUN-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 7/13/2011
327 SRSV - SUBPOENA RETURNED /
SERVED
Filing Date: 08-JUN-2011
Filing Party:
Disposition Amount:
Docket Text: none.
328 REQP - REQUEST TO PRODUCE
Filing Date: 09-JUN-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
329 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 09-JUN-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
330 NCAN - NOTICE OF CANCELLATION
Filing Date: 09-JUN-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: IOF DEPOSITION
331 ANTI - ANSWER TO
INTERROGATORIES
Filing Date: 10-JUN-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
332 I NOTD - NOTICE OF TAKING
DEPOSITION
Intp://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doetcp_dIctrpt_docket report... 11/29/2011
EFTA01087239
- Not an Official Document Page 57 of 67
Filing Date: I22-JUN-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
333 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 24-JUN-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
334 NCAN - NOTICE OF CANCELLATION
Filing Date: 06-JUL-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: OF DEPOSITION DUCES TECUM
336 I MOT - MOTION
Filing Date: 12-JUL-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
MOTION FOR LEAVE TO USE DOCUMENTS PRODUCED UNDER
Docket Text:
CONFIDENTIALITY AGREEMENT
337 RESP - RESPONSE TO:
Filing Date: 12-JUL-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:_
DEFT/COUNTER-PLANTIFF, BRADLEY J. EDWARDS' MOTION
FOR PROTECTIVE ORDER REGARDING SUBPOENA TO
TRUSTEE, HERBERT STETTIN FOR RECORDS OF
Docket Text:
COMMUNICATIONS BY AND BETWEEN ROTHSTEIN,
ROSENFELDT & ADLER, P.A. AND GOVERNMENT/LAW
ENFORCEMENT OFFICERS
338 SRNS - SUBPOENA RETURNED / NOT
SERVED
Filing Date: 12-JUL-2011
Filing Party:
Disposition Amount:
http://courtcon.co.paltn-beach. fl.us/pls/jiwp/ekpublic_qry_doct.cp_dlctrpt_docket_report... 11/29/2011
EFTA01087240
- Not an Official Document Page 58 of 67
'Docket Text: 'none.
339 1 ORD - ORDER
Filing Date: j14-JUL-2011
Filing Party:
Disposition Amount:
ON DEFT/ COUNTER-DEFT'S MOTION FOR PROTECTIVE
ORDER IN REGARD TO THE DEPOSITION DUCES TECUM OF
RECORDS CUSTODIAN AND TRUSTEE HERBERT STETTIN.
Docket Text:
DEFT'S MOTION FOR PROTECTIVE ORDER IS GRANTED AND
THE OBJECTION TO PRODUCTION OF RECORDS IS HEREBY
GRANTED. D CROW
340 ORD - ORDER
Filing Date: 14-JUL-2011
Filing Party:
Disposition Amount:
ON MOTION FOR RECONSIDERATION IS DENIED EXCEPT AS
Docket Text: TO INTERR NO. 1 AND INTERR NO. 7. SEE ORDER. D CROW
341 SRSV - SUBPOENA RETURNED /
SERVED
Filing Date: 15-JUL-2011
Filing Party:
Disposition Amount:
Docket Text: none.
342 ORD - ORDER
Filing Date: 15-JUL-2011
Filing Party:
Disposition Amount:
OMNIBUS ORDER IN REGARD TO UPDATE DEPOSITION OF THE
Docket Text: PLAINTIFF. SEE ORDER. D CROW
343 RRTP - RESPONSE TO REQ TO
PRODUCE
Filing Date: 18-JUL-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
344 MOT - MOTION
http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_dIctrpt docket_report... 11/29/2011
EFTA01087241
- Not an Official Document Page 59 of 67
tiling Date: 19-JUL-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
FOR LEAVE TO AMEND TO ASSERT A CLAIM FOR PUNITIVE
Docket Text:
DAMAGES
345 ORD - ORDER
Filing Date: 25-JUL-2011
Filing Party:
Disposition Amount:
ON PLT/COUNTER-DFT JEFFREY EPSTEIN'S MOTION FOR
Docket Text: LEAVE TO USE DOCUMENTS PRODUCED UNDER
CONFIDENTIALITY AGREEMENT. GRANTED. M SASSER
346 - I ORD - ORDER
Filing Date: 25-JUL-2011
Filing Party:
Disposition Amount:
ON DEFT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS'
Docket Text: MOTION TO DISMISS PLAINTIFF, JEFFREY EPSTEIN'S
AMENDED COMPLAINT IS GRANTED. M SASSER
347 ORD - ORDER
.....c—
Filing Date: 25-JUL-2011
Filing Party:
Disposition Amount:
ON DEFT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS MOTION
Docket Text: FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES IS
DENIED. M SASSER
348 I ORD - ORDER
Filing Date: 25-JUL-2011
Filing Party:
Disposition Amount:
ON PLAINTIFF/COUNTER-DEFT, JEFFREY EPSTEIN'S AMENDED
MOTION FOR PROTECTIVE ORDER RELATING TO EXTRA
Docket Text:
JUDICIAL STATEMENTS SERVED ON MAY 2, 2011 IS DENIED. M
SASSER
349 — Islip - SUPPLEMENT
Filing Date: 29-JUL-2011
Filing Party: EDWARDS, BRADLEY J
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_clidipt docket report... 11/29/2011
EFTA01087242
- Not an Official Document Page 60 of 67
Disposition Amount:
TO BRADLEY EDWARDS' PROFFER IN SUPPORT OF MOTION
Docket Text: FOR LEAVE TO AMEND TO ASSERT CLAIM FOR PUNITIVE
DAMAGES
350 NOT - NOTICE
Filing Date: 05-AUG-2011
Filing Party:
Disposition Amount:
Docket Text: CORRECTED NOTICE OF LIMITED APPEARANCE
351 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 12-AUG-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
352 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 12-AUG-2011
Filing Party: SCAROLA , ESQ, JACK
[Disposition Amount:
Docket Text: none.
353 NOUN - NOTICE OF UNAVAILABILITY
Filing Date: 12-AUG-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: none.
354 l MOT - MOTION
Filing Date: 15-AUG-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
FOR ENLARGEMENT OF TIME TO SERVE SECOND AMENDED
Docket Text:
COMPLAINT
355 NOH - NOTICE OF HEARING
Filing Date: 15-AUG-2011
Filing Party: EPSTEIN, JEFFREY
r
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public qry_doct.cp_dktrpt_docket_report... 11/29/2011
EFTA01087243
- Not an Official Document Page 61 of 67
'Disposition Amount
Docket Text: 8/18/2011
356 ORD - ORDER
Filing Date: 18-AUG-2011
Filing Party:
Disposition Amount:
GRANTING MOTION TO ENLARGE TIME: GRANTED. SEE
Docket Text:
ORDER. D CROW
357 CMP - COMPLAINT
Filing Date: 22-AUG-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: SECOND AMENDED
358 SRSV - SUBPOENA RETURNED /
SERVED
Filing Date: 23-AUG-2011
Filing Party:
Disposition Amount:
Docket Text: none.
359 NOT - NOTICE
Filing Date: 24-AUG-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: OF SCRIVENER'S ERRORS
360 MDIS - MOTION TO DISMISS
Filin. Date: 24-AUG-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: SECOND AMENDED COMPLAINT
361 MOT - MOTION
Filing Date: 29-AUG-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
TO SCHEDULE DEFT/COUNTER-PLAINTIFF'S PENDING
Docket Text:
MOTIONS FOR HEARING
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_publicAry doct.cp_clictrpt_docket report... 11/29/2011
EFTA01087244
- Not an Official Document Page 62 of 67
362 NOH - NOTICE OF HEARING
Filing Date: 29-AUG-2011
Filing Party: !EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: 8/31/2011
363 NOS - NOTICE OF SERVICE
30-AUG-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: PROPOSAL FOR SETTLEMENT
364 MTWD - MOTION TO WITHDRAW
Filing Date: 31-AUG-2011
Filing Party:
Disposition Amount:
MARTIN G. WEINBERG. MOTION TO WITHDRAW PRO HAC VICE
Docket Text: APPEARANCE AS COUNSEL FOR PLAINTIFF, JEFFREY EPSTEIN
& CONSENT THERETO
365 NOH - NOTICE OF HEARING
Filing Date: 31-AUG-2011
Filing Party: ACKERMAN , ESQ, JOSEPH L
Disposition Amount:
Docket Text: 9/8/2011
366 ORD - ORDER
Filing Date: 31-AUG-2011
Filing Party:
Disposition Amount:
ON MOTION TO SCHEDULE DEFT/COUNTER-PLAINTIFF'S
Docket Text:
PENDING MOTIONS FOR HEARING IS GRANTED. D CROW
367 jNOS - NOTICE OF SERVICE
Filing Date: 31-AUG-2011
Filing Party.:_ EPSTEIN, JEFFREY
Disposition Amount:
PROPOSAL FOR SETTLEMENT TO DEFT/COUNTER-PLAINTIFF
Docket Text:
BRADLEY J. EDWARDS, INDIVIDUALLY
368 I NOH - NOTICE OF HEARING
http://courtcon.co.nalm-beach.fLus/p1s/jiwp/ck_public_qry_doetep_dktipt_docket report... 11/29/2011
EFTA01087245
- Not an Official Document Page 63 of 67
Filing Date: 01-SEP-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: 19/28/2011
369 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 06-SEP-2011
Filing Party:
Disposition Amount:
Docket Text: CHANGING TIME ONLY
370 NCAN - NOTICE OF CANCELLATION
Filing Date: 09-SEP-2011
Filing Party:
Disposition Amount:
Docket Text: IOF HEARING ON SEPT 8 2011
371 AGOR - AGREED ORDER
Filing Date: 12-SEP-2011
Filing Party:
Disposition Amount:
ON MOTION TO WITHDRAW AS COUNSEL OF RECORD IS
Docket Text:
GRANTED. D CROW
372 RPRS - REPLY/RESPONSE
Filing Date: 22-SEP-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
RESPONSE IN OPPOSITION TO DEFT/COUNTER-PLAINTIFF
BRADLEY EDWARDS' MOTION FOR LEAVE TO AMEND TO
Docket Text:
ASSERT A CLAIM FOR PUNITIVE DAMAGES AND SUPPLEMENT
THERETO
373 MOT - MOTION
Filing Date: 22-SEP-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
MOTION FOR LEAVE TO EXCEED PAGE LIMIT IN RESPONSE TO
Docket Text: EDWARDS' MOTION FOR LEAVE TO AMEND TO ADD PUNITIVE
DAMAGES
http://courtcon.co.palm-beachAus/pls/jiwpick_public_qty_doct.cp_dktrpt_docket_report II/29/201i
EFTA01087246
- Not an Official Document Page 64 of 67
374 I RPRS - REPLY/RESPONSE
Filing Date: 22-SEP-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
RESPONSE IN OPPOSITION TO DEFT/COUNTER-PLAINTIFF
Docket Text: BRADLEY EDWARDS' MOTION TO DISMISS THE CORRECTED
SECOND AMENDED COMPLAINT
375 I AGOR - AGREED ORDER
Filing Date: 03-OCT-2011
Filing Party:
Disposition Amount: i
AGREED ORDER ON DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS' ORE TENUS MOTION TO AMEND
Docket Text:
COUNTERCLAIM: GRANTED. 15 DAYS TO FIEL AMENDMENTS
TO HIS COUNTERCLAIM. D CROW
376 I AGOR - AGREED ORDER
Filing Date: 03-OCT-2011
Filing Party:
Disposition Amount:
ION MOTION FOR LEAVE TO EXCEED PAGE LIMIT IN RESPONSE
Docket Text: TO EDWARDS' MOTION TO AMEND TO ADD PUNITIVE
IDAMAGES IS GRANTED. D CROW
377 COCL - COUNTERCLAIM
Filing Date: '04-OCT-2011
Filing Party: 'EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: AMENDED
378 ORD - ORDER
Filing Date: 04-OCT-2011
Filing Party:
Disposition Amount:
ON MOTION TO DISMISS PLAINTIFF'S SECOND AMENDED
Docket Text:
COMPLAINT D. CROW
379 MOT - MOTION
,. ..-
FIling Date: 05-OCT-2011
Filing Party: EDWARDS, BRADLEY J
I
http://couricon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11/29/2011
EFTA01087247
- Not an Official Document Page 65 of 67
Disposition Amount: 1
Docket Text: FOR ATTY'S FEES
380 MDIS - MOTION TO DISMISS
Filing Date: 21-OCT-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
AMENDED COUNTERCLAIM AND INCORPORATED
Docket Text:
MEMORANDUM OF LAW
381 NOUN - NOTICE OF UNAVAILABILITY
Filing Date: 25-OCT-2011
Filing Party: SCAROLA ESQ, JACK
Disposition Amount:
Docket Text: 'none.
382 NOFI - NOTICE OF FILING
INTERROGS
Filing Date: 28-OCT-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
383 ANAD - ANSWER & AFFIRMATIVE
DEFENSES
Filing Date ^ 28-OCT-2011
Filing Party: _ EDWARDS, BRADLEY J
Disposition Amour l
Docket Text: ITO SECOND AMENDED COMPLAINT
384 REQP - REQUEST TO PRODUCE
Filing Date: 28-OCT-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
385 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 31-OCT-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
•
http://courtcon.co.palm-beach.fLus/pIs/jiwp/ck_public_qry_doct.cp dktrpt_docket_report... 11/29/2011
EFTA01087248
- Not an Official Document Page 66 of 67
RENEWED MOTION FOR PROTECTIVE ORDER RELATING TO
Docket Text:
HIS DEPOSITION
386 RPRS - REPLY/RESPONSE
Filing Date: 31-OCT-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
IN OPPOSITION TO DEFT/COUNTERPLAINTIFF BRADLEY J.
Docket Text:
EDWARDS' MOTION FOR ATTORNEY'S FEES
387 RNTD - RE-NOTICE OF TAKING
DEPOSITION
Filing Date: 02-NOV-2011
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
388 NOH - NOTICE OF HEARING
Filing Date: IR2±1O\ 11
Filing Party: 'EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 111/9/2011
389 NOH - NOTICE OF HEARING
Filing Date: 03-NOV-2011
Filing Party: IEPSTEIN, JEFFREY
il
Disposition Amount:
Docket Text: 111/21/2011
390 MOT - MOTION
Filing Date: 104-NOV-2011
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: RENEWED MOTION FOR FINAL SUMMARY JUDGMENT
391 NOH - NOTICE OF HEARING
Filing Date: 07-NOV-2011
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docke
DataSet-9
Unknown
1 pages
From:
To: jeevaeationggmail.com
Subject: Re:
Date: Sun, 06 May 2012 14:40:31 +0000
just finished reading 2 volumes of Edwards deposition, and excerpts of scott re adler. Adler won't be happy Scott said he's not
""" the sharpest pencil in the box" Meeting adler for a beer at beach club later today. Will talk to you Im not nuts about email of
text. Too many eyes.
Original Message
From: Jeffrey Epstein <'eevacation mail.corn>
To: Fred Haddad <
Sent: Sun, May 6, 2012 7:39 am
that was fun. lets talk tomorrow for a few minutes
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation(@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA00702180
DataSet-9
Unknown
2 pages
May 25. Wednesday
8:15 Breakfast with Jay Lefkowitz (Jay:
10:00 Meet Chris Knight in the lobby of Dewe and LeBoeuf
1301 Ave. of the America's, 23rd Floor,
Chris Knight ell
10:30 AJ Discala deposition
4:00 Appt w/Dangene and Jennie at the Core Club
66 e. 55th street bet Park and Madison
5:15 Appt w/George Delson at his office (Darren and Rich to
meet you there. Skip Evans to attend meeting as well)
One Dag Hammarskjold Plaza
885 Second Ave, 26th Floor
6:00 YOU are to call Stewart Coulter re David Gelenter
Stewart:
May 26. Thursday
8:00 Breakfast with Roy Black (Roy:
10:00 Appt w/Little Katya
10:00 Susman Conf. Call Tel: Password:
1:00 Lunch w/Katherine Keating
EFTA00307026
3:30 Take Celina shopping
May 27, Friday
2:00 TENATIVE Lunch with Reid Weingarten ( I
4:30 A t w Nathan Myhrvold
EFTA00307027
DataSet-11
Unknown
2 pages
From:
Sent: Thursda October 25, 2018 6:44 PM
To:
Subject: Re:
Of course not
On Thu, Oct 25, 2018 at 2:42 P
wrote:
Did you write deposition against me?
LIT, 25 OKT. 2018=r. a 14:29, l
On Thu, Oct =5, 2018 at 1:58 PM
> wrote:
<=lockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:lpx=itccc solid;padding-left:lex">
Killers: Prokhorov and Baib=kov (plus all his people), Zampolli Paolo, Anna Konchakovskaya and all
peo=le who work for them. Prokhorov has a lot to hide
please notear>
The information contained in this communication is
confidential,=may be attorney-client privileged, may
constitute inside information, a=d is intended only for
the use of the addressee. It is the property ofar>JEE
Unauthorized use, disclosure or copying of this
communication =r any part thereof is strictly prohibited
and may be unlawful. If you h=ve received this
communication in error, please notify us immediately b=
return e-mail or by e-mail to [email protected] , and
destroy this communica=ion and all copies thereof,
including all attachments. copyright -all r=ghts reserved
Q=A0 please note
The information contained in this=communication is
confidential, may be attorney-client privileged, mayconstitute inside information, and is intended only for
the use of the=addressee. It is the property of
JEE
EFTA_R1_01822677
EFTA02618674
Unauthorized use, disclosure or=copying of this
communication or any part thereof is strictly prohibite=
and may be unlawful. If you have received this
communication in err=r, please notify us immediately by
return e-mail or by e-mail to [email protected]<=a>, and
destroy this communication and all copies thereof,
including=all attachments. copyright -all rights reserved
--00O00O0O0000ae07f7057911fd5d-- conversation-id 323905 date-last-viewed 0 date-received 1540493060
flags 8590195713 remote-id 865936
2
EFTA_R1_01822678
EFTA02618675
DataSet-9
Unknown
1 pages
AUG-06-09 09:54 FROYFLEOPOLD%KUVIN,. 15615151401 1-361 P.001/001 F-984
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA0373193000CMB AB
Plaintiff,
VS.
JEFFREY EPSTEIN
Defendant.
ED VIDEOTAPED DEPOSITION
PLAINTIFF'S NOTICE OF TAKING CONTINU
WILL TAKE THE DEPOSITION OF:
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY
DATE AND TIME: LOCATION:
NAME;
August 7, 2009 Kress Court Reporting
Alfredo Rodriguez
1:00 PM 1031 Ives Dairy Road
Suite 228, Bldg 4
North Miami, FL 33179
by law to take depositions in
upon an oral examination before a Notary Public or officer authorized
ue from day to day until completed. The
the State of Florida. The oral examination will contin
at trial or are being taken for such
depositions are being taken for purposes of discovery, for use
other purposes as are permitted under the Rules of the Court.
e was faxed and mailed
I HEREBY CERTIFY that a true and correct copy of this Notic
Australian Avenue, Suite 1400,
this 41 day of August, 2009 to: Jack A. Goldberger, Esq., 250
Australian Avenue South, Suite 1400,
West Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250
J. Pike, 515 North Flagler Drive,
West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael
Suite 400, West Palm Beach, FL 33401.
LEOPOLD—KUVN, P.A.
2925 PGA Boulevard, Suite 200
s, FL 33410
By:
Sy N KUVIN, ESQ.
Florid a Bar No: 089737
EFTA00722928
DataSet-9
Unknown
1 pages
From: (CID) (FBI)" alMIE>
To: (NY) (FBI)" la
Subject: JE
Date: Wed, 24 Jun 2020 14:06:07 +0000
Importance: Normal
Thanks
On Jun 24, 2020 10:05 AM, ' (NY) (FBI)" ..ta wrote:
She lied during a 2016 civil deposition where she was asked specific questions about her involvement with
Epstein.
SSA -
FBI New York
On Jun 24, 2020 10:02 AM, ' (CID) (FBI)" c wrote:
Sean,
One additional question: What is the basis for the perjury charge?
Thanks,
EFTA00147931
DataSet-9
Unknown
118 pages
-0929104.TXT
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2006 CF09454AXX
STATE OF FLORIDA,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
Pall,11,91,,11ouse
205 North Dixie Highway
West Palm Beach, Florida 33401
Reported By:
Judith F. Consor, FPR
Notary Public, State of Florida
Consor-Reporting and Transcription
Phone
1 APPEARANCES:
2 On behalf of the State:
3 ESQ.
ATTORNEY
4 401 North Dixie Highway
ach, Florida 33401
5
6 On behalf of the Defendant:
7 MICHAEL R. TEIN, ESQ.
KATHRYN A. MEYERS, ESQ.
8 LEWIS TEIN, PL
3059 GRAND AVENUE, SUITE 340
Page 1
EFTA00801875
-0929104.TXT
9 COCONUT GROVE, FL 33133
10
On behalf of the Defendant:
11 JACK A. GOLDBERGER, ESQ.
ATTERBURY, GOLDBERGER & WEISS
12 250 AUSTRALIAN AVENUE SOUTH
SUITE 1400
13 ACH, FLORIDA 33401
14
15 ALSO PRESENT:
KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION,
16 LEGAL-EZE
17
18
19
20
21
22
23
24
25
1 INDEX
2 WITNESS: PAGE:
3
I III I IMT ION 4
4 BY MR. TEIN:
5
6
7 NO EXHIBITS MARKED
8
9
10
11
12
13
Page 2
EFTA00801876
-0929104.TXT
14
15
16
17
18
19
20
21
22
23
24
25
4
1 Deposition taken before Judith F. Consor,
2 Court Reporter and Notary Public in and for the State of
3 Florida at Large, in the above cause.
4
5 Thereupon,
6
7 having been first duly sworn or affirmed, was examined
8 and testified as follows:
9 THE WITNESS: I do.
10 DIRECT EXAMINATION
11 BY MR. TEIN:
12 O. Good afternoon. Please tell me your full
13 name.
14 A.
15 0. And can you please spell it?
16 A.
Page 3
EFTA00801877
-0929104.TXT
18 O. Thank you.
19 May I call you
20 A. Uh-huh.
21 O. , I'm going to ask you a few
22 questions, several questions today. If at any time you
23 want to take a break, you just let me know. Okay?
24 A. Okay.
25 O. If you at any time don't understand one of
1 my questions, will you just please let me know?
2 A. Yes.
3 O. And if at any time you're not feeling well
4 or something like that, you'll tell us, right?
5 A. Yes.
6 O. Do you feel okay today?
7 A. Yes.
8 O. Not taking any alcohol or drugs or anything
9 like that, right?
10 A. No.
11 O. So you feel ready to have your deposition
12 taken?
13 A. Yes.
14 O. what is your address?
15 A. I'm currently living at house and
16 I don't know it off the top of my head.
17 O. Where is it?
18 A.
19 O. Who is your aunt?
20 A.
21 O. Who else is living there?
22 A.
age
EFTA00801878
-0929104.TXT
23 O. Anyone else living there?
24 A. No.
25 O.
1
says that you live with
3 and have been living there; is that
4 correct?
5 A. Yes.
6 O. How long have you been living with your
7
8 A. Since
9 O. That was Thanksgiving of this past year?
10 A. Yes, sir.
11 O. Okay. Didn't did your
get an apartment for the two of
13 you?
14 A. No, sir. He has an apartment, but by
15 himself.
16 O. Did he get an apartment for the two of you
17 to live in?
18 A. No, sir.
19 O. Are you planning to move in with him?
20 A. Maybe one day in the future.
21 O. Do you have a plan to move in with him
22 presently?
23 A. No.
24 O. Have you been to the apartment that you and
25 have discussed moving in together?
Page 5
EFTA00801879
-0929104.TXT
7
1 A. I have been to the apartment.
2 O. Where is that?
3 A.
4 O. Have you spent the night over there?
5 A. No, sir.
6 O. Do you know the address there?
7 A. I do not.
8 O. Isn't planning on living
9 with you
10 A. No.
11 O. , you know that this court case is a
12 criminal prosecution, correct?
13 A. Correct.
14 O. And you know that it's a criminal
15 prosecution against a man who has no criminal background.
16 Do you know that?
17 A. I do now.
18 O. You agree that court is a very serious
19 matter?
20 A. Yes.
21 O. And you're here with your lawyer
22 right?
23 A. Yes.
24 O. And you know that recently
25
8
1
2 : Let me just object.
3 , let me instruct you. Anything that
4 you have learned through conversations between you
Page 6
EFTA00801880
-0929104.TXT
5 and me are protected. So if you know any of that
6 information outside of those discussions, you may
7 answer. But if the only way you know it is
8 through our discussions, do not answer that
9 question.
10 BY MR. TEIN:
11 O. , you know that recently
12
14 : Same objection.
15 If you know the answer to that outside of
16 our discussions, you may answer. If it is the
17 only way that you know the answer is through our
18 discussions, do not answer that question.
19 THE WITNESS: Okay.
20 : Attorney/client privilege.
21 BY MR. TEIN:
22 O. You can answer the question unless --
23 : Same objection.
24 MR. TEIN: Let me finish.
25 : Excuse me. We're --
1 MR. TEIN: No. Let me finish.
2 : Lewis, we're not going to do
3 that.
4 MR. TEIN: My name is not Lewis.
5 I'm going to finish my question. Okay?
6 : Do not answer until you hear
7 from me.
8 BY MR. TEIN:
Page 7
EFTA00801881
-0929104.TXT
9 O. Other than conversations that you have had
10 with -- I'm not asking about that -- are you
11 aware that
14 : Same objection.
15 Anything that you learn through
16 conversations between you and me, do not answer.
17 Those are protected. If you know through any
18 other realm of knowledge, you may answer.
19 THE WITNESS: No.
20 BY MR. TEIN:
21 O. You have no idea that
24 : Same objection.
25 Do not answer that question if it's through
10
1 discussions that you and I had. Outside of that,
2 you may answer. So do not answer that question if
3 that is the only basis by which you understand
4 that answer.
5 THE WITNESS: No.
6 BY MR. TEIN:
7 O. You didn't know that?
8 : Don't answer that question.
9 Against, it's attorney/client privilege. Any
10 information you've learned through conversations
11 between you and I are protected. If you know it
12 through any other realm, you may answer.
13 MR. TEIN: Are you going to say that for
Page 8
EFTA00801882
-0929104.TXT
14 every question in the deposition, 7
15 : When you ask improper
16 questions like that without the proper --
17 MR. TEIN: You're going to stop your
18 speaking objections right now. Okay?
19 : Without the proper
20 MR. TEIN: You need to stop your speaking
21 objections.
22 Let's continue.
23 : Counsel, you just asked me a
24 question and I'm going to state it on the
25 record --
11
1 MR. TEIN: You need to stop your speaking
2 objections. Check your rules.
3 : Excuse me. For the record,
4 Counsel asked me a question. I'll state the
5 answer on the record. He asked me the question am
6 I going to be answering that way throughout the
7 deposition. So long as there's improper
8 foundation and predicate asked by the attorney, I
9 will protect my client and I make the record where
10 appropriate. If counsel wishes to ask an
11 appropriate worded question with the proper
12 foundation and predicate, I will certainly allow
13 the client to answer the question.
14 MR. GOLDBERGER: Why don't you just state
15 attorney/client privilege and just be done with
16 it.
17 : I want the record to be
Page 9
EFTA00801883
-0929104.TXT
18 clear.
19 MR. TEIN: You want to waste time is what
20 you want to do. You were supposed to be here this
21 morning and you totally broke the deal, the
22 agreement that you had with us if your hearing got
23 cancelled.
24 But let's move on and maybe you'll stop
25 obstructing this deposition.
12
1 : I think the record is very
2 clear where we stand thus far.
3 Is there a recording taken of this
4 deposition?
5 THE COURT REPORTER: Yes.
6 : Just make sure that's
7 preserved.
8 BY MR. TEIN:
9 O. Go to Exhibit -- well, before you do
10 that, , are you aware that
9
12 : Objection.
13 Any conversations that you and I have had
14 regarding that, if that is the only way by which
15 you understand how to answer that question, so not
16 answer. It's attorney/client privilege, as well
17 as any conversations you may have had with the
18 attorney That is also attorney/client
19 privilege. And I'm assuming --
20 MR. TEIN: You're actually wrong about the
21 attorney/client privilege.
22 : I'm assuming Counsel is not
Page 10
EFTA00801884
-0929104.TXT
23 asking you to divulge attorney/client
24 MR. TEIN: Of course not.
25 BY MR. TEIN:
13
1 O. , are you aware that
4 : Same objection.
5 MR. TEIN: We've heard the objection 10
6 times already.
7 : Counsel, excuse me.
8 MR. TEIN: Just say attorney/client
9 privilege. Stop interrupting my questions.
10 : I'm entitled to make an
11 objection for the record, which I'm doing, and
12 I'll make the same objection. And if it calls for
13 attorney/client privilege, any conversations you
14 and I have had, do not answer the question.
15 And I think that it might be appropriate
16 for the record to ask questions via Ms.
17 as opposed to . I think that would be more
18 appropriate for this deposition.
19 BY MR. TEIN:
20 O. Go ahead. Please answer yes or no.
21 A. Yes.
22 O. Thank you.
23 In fact, you know that
, don't you?
Page 11
EFTA00801885
-0929104.TXT
14
1 A. After it happened.
2 O. You know that
3 don't you, yes or no?
4 A. Yes.
5 O. In fact, let's go to Exhibit
6 MR. GOLDBERGER: Look behind you. You'll
7 see it.
8 BY MR. TEIN:
9 O. Have you ever seen that picture before?
10 A. Yes.
11 O. Is that a picture of
14 A. Yes.
15 O. Now you know that this is a very serious
16 matter, don't you?
17 : Asked and answered.
18 Objection.
19 MR. GOLDBERGER: All right. You can
20 object. You're representing a witness here,
21 . You can object on privilege grounds.
22 You cannot make legal objections. You have no
23 standing to do so.
24 : I'm going to make them and
25 then --
15
1 MR. GOLDBERGER: We're --
2 : We're going to leave or we're
3 going to take a break because his demeanor is not
4 appropriate. There's no reason to have this kind
Page 12
EFTA00801886
-0929104.TXT
5 of demeanor. If you want to have this kind of
6 demeanor with me
7 MR. TEIN: You are obstructing this
8 deposition.
9 MR. GOLDBERGER: Why don't you guys go
10 outside and just talk about --
11 : She -- her job is very
12 difficult and she's not going to be able to take
13 us both talking at he same time.
14 MR. GOLDBERGER: Off the record.
15 : We're not going off the
16 record, Jack. We're not, Jack. Her job is very
17 difficult. I'm going to make the record.
18 I don't think it is appropriate, especially
19 in the small confines of this room, to be very
20 aggressive with this young lady.
21 MR. TEIN: That's not happening. Stop,
22 stop actually --
23 : If you're going to interrupt
24 me, we're going to cancel this deposition
25 MR. TEIN: Stop misrepresenting.
16
1 THE COURT REPORTER: I need on at a time,
2 no matter who it is.
3 : I think we're going to take a
4 break. Perhaps you might want to talk to your
5 co-counsel --
6 MR. TEIN: I don't need to talk to him.
7 : But we're going to take a
8 break.
Page 13
EFTA00801887
-0929104.TXT
9 MR. TEIN: Not taking a break unless the
10 witness needs a break.
11 You're obstructing this deposition, III.
12 : Come on,
13 You all want to continue in this
14 demeanor --
15 MR. TEIN: You're obstructing the
16 deposition. Stop making speeches. We're not
17 discussing this with you. The questions are to
18 your client. Go take your five-minute break.
19 : Fine. We need to make sure
20 the record's clear and clean.
21 And I want to make sure as I've already
22 asked you -- I know that you're one of the best in
23 town -- that this audio -- this needs to be
24 preserved. Okay?
25 MR. TEIN: Go take your five-minute break,
17
1 , now.
2 You were supposed to be here at nine a.m.;
3 it's now after two. Take your break and come
4 back.
5 : Okay. If the demeanor keeps
6 up, we will not be here beyond those five minutes.
7 MR. TEIN: Take your break and come back.
8 : Okay. So I suggest that you
9 relax.
10 MR. TEIN: I suggest that you take your
11 break.
12 MR. GOLDBERGER: Let them take that
13 five-minute break.
Page 14
EFTA00801888
-0929104.TXT
14 : But I would suggest that you
15 take deep breaths.
16 MR. TEIN: Suggest whatever you want. Go
17 take a break.
18 (Thereupon, a recess was taken.)
19 BY MR. TEIN:
20 O. you agree that giving testimony
21 today at your deposition is something very serious, don't
22 you?
23 A. Yes.
24 O. And you respect the court, don't you?
25 A. Yes.
18
1 O. Let me show you Exhibit . Can you
2 read that out loud, please?
3 A. Okay. What do you want?
4 O. Will you read that out loud, please.
5 A. Oh.
6 O. Thank you.
7 A. Lol hah my baddd...lol yah i got some
8 stupid court shit ...bullshit...and damn you
9 still have court shit with him? Like after so long wow
10 im sorry... well yah well we will definitely havta make
11 plans for sure..because i miss u tons times a million and
12 no no no i love you...o p.s. i love ur default pic
13 niggaa. Muah xo.
14 O. Did you send that message last week to a
15 friend of yours on MySpace?
16 A. I wouldn't know. There's no dates and I've
17 deleted that MySpace, so --
Page 15
EFTA00801889
-0929104.TXT
18 O. We're going to talk about that in a second.
19 A. Okay.
20 O. Did you send that message last week
21 A. Right.
22 O. Let me finish my question.
23 Did you send that message last week to a
24 friend of yours on MySpace?
25 A. I wouldn't know the date, but obviously,
19
1 it's to a friend.
2 O. Did you send that message to a friend of
3 yours on MySpace?
4 A. Sure, yes.
5 O. Were you referring to this deposition?
6 A. Yes.
7 O. Do you find the term n-i-g-g-e-r offensive?
8 A. That's not anywhere in there.
9 O. What word did you use in there?
10 : Where are you referring to,
11 Counsel? There's 20 plus words in there.
12 MR. TEIN: Don't make a speaking objection.
13 THE WITNESS: Are you referring to
14 anything --
15 : No, . Don't -- don't --
16 let him ask you the question.
17 BY MR. TEIN:
18 O. What question were you asking, 7
19 : She doesn't ask questions.
20 You ask the questions. What is the question
21 pending?
22 BY MR. TEIN:
Page 16
EFTA00801890
-0929104.TXT
23 O. , what is the last word on there in
24 the text of your message before the closing?
25 A. Niggaa.
20
1 O. Don't you find that term offensive?
2 A. No.
3 : Can you spell it for the
4 record, please.
5 THE WITNESS: N-i-g-g --
6 MR. TEIN: No, no, no. You are not going
7 to be asking questions.
8 : I'm not asking questions.
9 I'm asking for the record the word to be spelled
10 because we don't have a video here today.
11 MR. TEIN: These exhibits are part of the
12 record. You --
13 : Well, it's not marked as an
14 exhibit.
15 MR. TEIN: Stop interrupting me,
16 . I have marked and identified as an
17 exhibit and you will get it.
18 : There has been no
19 identification of this document in the record.
20 MR. TEIN: , stop interrupting
21 this deposition.
22 : What is the exhibit number
23 marked for identification?
24 MR. TEIN:
25 : Do we have copies? Is it on
Page 17
EFTA00801891
-0929104.TXT
21
1 the record anywhere?
2 BY MR. TEIN:
3 O. Let me ask you, , did you in fact
4 write your friend this message about this deposition?
5 A. Yes.
6 O. So you wrote your friend that this
7 deposition is stupid court s-h-i-t, correct?
8 A. Yes.
9 O. Because you think this deposition is stupid
10 court s-h-i-t, don't you?
11 A. No.
12 O. You wrote that to your friend, didn't you?
13 A. Yes.
14 O. You think that court is stupid, don't you?
15 A. In some cases.
16 O. And you think that court is bull s-h-i-t,
17 don't you?
18 A. No.
19 O. And you think this deposition is bull
20 s-h-i-t, don't you?
21 A. No.
22 O. You wrote that to your friend, didn't you?
23 : Objection. Asked and
24 answered.
25 MR. TEIN: That's not an objection.
22
1 BY MR. TEIN:
2 O. You wrote that to your friend, didn't you?
3 : Objection. Asked and
4 answered, for the fourth time.
Page 18
EFTA00801892
-0929104.TXT
5 MR. TEIN: You are improperly objecting,
6 . You have no grounds to object. And
7 that's not an objection.
8 : It is an objection.
9 MR. TEIN: Then terminate the deposition if
10 you think it's been asked and answered.
11 : Counsel, I am not precluded
12 from just making an objection to the form of the
13 question. As the courts well know, and if you
14 practice here in West Palm Beach, many of the
15 judges require you to set the objection with
16 specificity. And I will do that. And if you
17 don't want me to, you can make the record. But
18 will do that.
19 MR. TEIN: Here's what we'll do, III. You
20 can -- I will allow you to reserve an objection to
21 form for every single one of my questions.
22 Otherwise, all you're doing is obstructing.
23 : I won't do that.
24 MR. TEIN: Of course; because you want to
25 obstruct.
23
1 : All right.
2 BY MR. TEIN:
3 O. , you think that giving testimony
4 today, under oath, is bull s-h-i-t, don't you?
5 A. No.
6 O. And you wrote that to your friend on
7 MySpace last week, didn't you?
8 : Objection. Asked and
Page 19
EFTA00801893
-0929104.TXT
9 answered.
10 THE WITNESS: No, I did not.
11 BY MR. TEIN:
12 O. You didn't write this exhibit?
13 A. I wrote that, but I didn't write what you
14 said.
15 O. You wrote in this exhibit, "I got some
16 stupid court s-h-i-t Bull s-h-i-t." Didn't
17 you write that?
18 A. Yes.
19 O. Referring to this deposition, didn't you?
20 A. Referring to the court. I was later
21 informed that it was a deposition.
22 O. I'm going to ask you some questions now
23 about what happened when you went to Jeff Epstein's house
24 years ago. Okay?
25 A. Uh-huh.
24
1 O. When the police interviewed you
2 after you went to Epstein's house, you swore on your
3 mother's grave that you and Epstein did not engage in sex
4 of any kind?
5 A. Yes.
6 O. Didn't you tell that to the police?
7 A. Yes. And I will continue. I have never
8 had sex with him.
9 O. Did what happened upstairs at Jeff
10 Epstein's house take you completely by surprise,
11 A. Yes.
12 O. Now the
Page 20
EFTA00801894
-0929104_TXT
14
16 A. Yes.
17 0. Were you totally shocked by what happened
18 when you got to Epstein's house?
19 A. Yes.
20 0. You didn't expect it at all, did you?
21 A. No.
22 0. You had absolutely no idea why your friend
23 was taking you to Epstein's shoes, right?
24 A. I was informed it was a massage.
25 Q. All you thought that it was going to be was
25
1 a massage, correct?
2 A. Yes.
3 0. Before you got to Epstein's house
4 never said anything to you on the telephone about sexual
5 activity with Epstein, did he?
6 A. No.
7 0. And before you got to Epstein's house
8 never sent you a message over the Internet about
9 sexual activity with Epstein, did she?
10 A. No.
11 0. Did ever try to convince you to
12 engage in any sexual activity with Epstein?
13 A. No.
14 0. Did every try to convince
15 you to engage in any sexual activity with Epstein?
16 A. I don't know who is.
17 0. Do you have a friend
Page 21
EFTA00801895
-0929104.TXT
18 A. No.
19 O. Okay. Before you went so Epstein's house
20 did anyone call or e-mail you to induce you to engage in
21 sexual activity with Epstein?
22 A. No.
23 O. So you're sure that before you got to
24 Epstein's house no one tried to persuade you to engage in
25 sexual activity with Epstein?
26
1 A. No.
2 O. You're sure that -- let me ask the question
3 again.
4 You're sure that before you got to
5 Epstein's house no one tried to persuade you to engage in
6 sexual activity with Epstein for money. Are you?
7 : Objection. Asked and
8 answered.
9 THE WITNESS: No. And I've already
10 answered that a bazillion times.
11 BY MR. TEIN:
12 O. He's coaching you now. So I'm going to ask
13 the question
14 : Counsel, I've made an
15 objection for the record.
16 MR. TEIN: Stop speaking.
17 : I'm not going to stop
18 speaking. You can't interrupt me when I'm making
19 the record.
20 MR. TEIN: You're coaching the witness.
21 : Counsel --
22 MR. TEIN: Stop coaching the witness.
Page 22
EFTA00801896
-0929104.TXT
23 BY MR. TEIN:
24 O. , let me ask you --
25 : If you continue to --
27
1 MR. TEIN: Stop interrupting my questions.
2 : If you do it one more time,
3 we're leaving.
4 BY MR. TEIN:
5 O.
6 : I'm going to make the record.
7 You cannot interrupt me when I'm making the
8 record. Out of professional conduct, you cannot
9 do that. I'm entitled to make the record. I made
10 an objection, asked and answered. You demeanor is
11 inappropriate. You're willing and you are able
12 and you're responsible to ask a question in a
13 professional manner and ask the question and once
14 you get the answer, to either follow up on it or
15 move on, but not continuously browbeat and ask the
16 same question over and over because you don't like
17 the answer.
18 MR. TEIN: Calm down, sir.
19 : Trust me, I'm very calm here.
20 When I'm not calm you'll know it. I'm very calm.
21 So please continue on, but I will not allow
22 you to continue to harass her in the demeanor that
23 you're doing. Ask her a question and move on.
24 MR. TEIN: Are you done?
25 : Thank you. I am.
Page 23
EFTA00801897
-0929104.TXT
28
1 MR. TEIN: Stop misrepresenting the record
2 and calm down. I'm going to ask my question.
3 Stop it.
4 BY MR. TEIN:
5 O.
6 : I think the record is very
7 clear.
8 MR. GOLDBERGER: Let me just clarify
9 something. When you object to the form of a
10 question, you're not instructing the witness not
11 to answer the question, are you?
12 : No. And I'm not making that
13 objection; only on attorney/client privilege.
14 MR. TEIN: Will you stop speaking now so I
15 can ask my question? Are you done?
16 Okay. I'm going to ask my question.
17 BY MR. TEIN:
18 O. Listen,
19 : Hold on. Stop.
20 I've been doing this for 20 plus years and
21 have met a lot of attorneys, but I've never had an
22 experience like this where I've --
23 MR. TEIN: Stop your speeches.
24 : If you continue to do this,
25 whether it's with me or with my client, I will not
29
1 put up with it and I don't need to put up with it
2 and it's not appropriate. And I'm sure Mr.
3 Goldberger knows all this, because I know that he
4 wouldn't do this. So I will not put up with it.
Page 24
EFTA00801898
-0929104.TXT
5 And I think it's highly inappropriate to do this
6 with this child sitting here, the way you're
7 acting, primarily towards me, and I will not put
8 up with it.
9 MR. TEIN: Will you please stop your speech
10 so I can ask questions?
11 : So long as you act
12 professionally, I will do so. But if you continue
13 to do it this way, I will leave.
14 MR. TEIN: Suit yourself.
15 BY MR. TEIN:
16 O. , are you sure that before you got to
17 Epstein's house no one tried to persuade you to engage in
18 sexual activity with Epstein for money?
19 : Asked and answered.
20 Objection.
21 MR. TEIN: Did you get her answer?
22 THE COURT REPORTER: No, I did not.
23 THE WITNESS: I'm sure.
24 BY MR. TEIN:
25 O. Let me ask you a few questions about your
30
1 contact with Epstein. Okay?
2 A. (Witness nods head up and down.)
3 O. Jeff never e-mailed you, did he?
4 A. No.
5 O. Jeff never text messaged you, did he?
6 A. No.
7 O. Jeff never chatted in a chat room with you,
8 did he?
Page 25
EFTA00801899
-0929104.TXT
9 A. No.
10 O. Before you got to Epstein's house you had
11 never spoken to Jeff, had you?
12 A. No.
13 O. And before you got to Epstein's house you
14 had never met Jeff?
15 A. Correct.
16 O. Before you got to Epstein's house you had
17 never told Jeff that you were under 18, right?
18 A. No.
19 O. Before you got to Epstein's house had you
20 ever told that you were under 18?
21 A. No, I never spoke to the man before that.
22 O. And you only went to Jeff Epstein's house
23 that one time years ago, correct?
24 A. Yes.
25 O. You never went there again, correct?
31
1 A. No.
2 O. All right. Let me ask you two final areas
3 of questioning about this and we'll move onto something
4 else. Okay?
5 A. Uh-huh. Yes. I'm sorry.
6 O. Before you got to Epstein's did anyone
7 associated with Epstein ever call you on the phone and
8 try to persuade, induce, entice or coerce you to engage
9 in any sexual activity?
10 A. No.
11 O. Before you got to Epstein's did anybody
12 associated with Epstein ever contact you on the Internet
13 and try to persuade, induce, entice or coerce you to
Page 26
EFTA00801900
-0929104.TXT
14 engage in any sexual activity?
15 A. No.
16 O. , who told you that when you got to
17 Jeff Epstein's house you should lie to Jeff about your
18 age?
19 A.
20 O. Was it or was it the other girl in
21 the car who you rode over with to Epstein's house?
22 A.
23 O. Who was the other girl in the car with you
24 that day?
25 A. I honestly don't know.
32
1 O. Had you ever seen her before?
2 A. No, sir.
3 O. You told the police that when you rode over
4 to Epstein's you had no idea who she was, right?
5 A. Correct.
6 O. You told the police that you didn't know
7 her name, but she was
9
9 A. Yes.
10 O. Those were your words, right?
11 A. Yes.
12 O. Do you now know who she is?
13 A. No, sir.
14 O. So it was who told you to lie about
15 your age to Jeff Epstein?
16 A. Yes, sir.
17 O. And told you that if you weren't 18,
Page 27
EFTA00801901
-0929104.TXT
18 Epstein wouldn't let you into his house, right?
19 A. That's -- yes, yes.
20 O. All right. Let's talk for a minute about
21 when you first met Jeff. Okay?
22 A. Sure.
23 O. When you first met Jeff he tried to find
24 out how old you were, right?
25 A. Excuse me?
33
1 O. When you first met Jeff he tried to find
2 out how old you were, right?
3 A. Not when we first introduced each other;
4 when we get upstairs, then yes.
5 O. During the massage Jeff asked you how old
6 you were, correct?
7 A. Yes, yes.
8 O. Now hadn't you already told Jeff's
9 assistant, the one who walked you upstairs, that you went
10 to college and had just moved down here 7
11 A. I never spoke to the lady.
12 O. Do you want to rethink that answer?
13 : Is that a question?
14 BY MR. TEIN:
15 O. Do you want to rethink that answer?
16 A. No. I didn't really speak with her that
17 much.
18 O. Do you want to try to refresh your memory
19 on that?
20 : Do you have something to
21 refresh her memory with?
22 MR. TEIN: Do you want to stop making
Page 28
EFTA00801902
-0929104.TXT
23 speaking objections?
24 : No. But to refresh someone's
25 memory you show them a document.
34
1 MR. TEIN: I know how to do this.
2 : Then show her a document.
3 MR. TEIN: Stop speaking.
4 : I'm not going to stop
5 speaking. I'm going to continue to make the
6 record.
7 MR. TEIN: You're obstructing. Please
8 stop.
9 : I'm not obstructing. But if
10 you want to refresh her recollection, you need to
11 show her something.
12 That's not a proper question. I object to
13 the foundation and the predicate of that question.
14 MR. TEIN: Are you done?
15 : I am now. Thank you.
16 BY MR. TEIN:
17 O. Do you want to try to refresh your memory
18 as to whether you had any conversation with the woman who
19 walked you upstairs in Epstein's house in which you told
20 her that you went to college and had just moved down
21
22 : Objection. Object to the
23 form of the question. Lack of foundation and
24 predicate.
25 BY MR. TEIN:
Page 29
EFTA00801903
-0929104.TXT
35
1 O. You can answer the question.
2 A. Sure.
3 O. Is there anything that would refresh your
4 memory that in fact you told Mr. Epstein's assistant, the
5 one who walked you upstairs, that you went to college and
6 you had just moved down here 7
7 A. I don't remember saying that, but if you --
8 I don't remember saying that myself, so --
9 O. That would be a lie, right?
10 A. No. I really don't remember.
11 O. So you told Jeff that you were 18 years
12 old, correct?
13 A. Yes.
14 O. Do you remember of
15 the Police Department, Palm Beach Police Department,
16 A. Yes.
17 O. Do you remember you spoke to her?
18 A. Yes.
19 O. Do you remember that you told Detective
20 that when you lied about your age to Jeff
9
23 A. I don't remember the words exactly, but I
24 do remember telling her I told him I was 18.
25 O. And do you remember telling
36
1 that when you lied to Epstein about your age that-
4 A. No, I don't remember saying those words
Page 30
EFTA00801904
-0929104.TXT
5 exactly to her. I remember telling her that I told
6 Epstein I was 18.
7 O. Does it sound right to you that you told
8
10 MS. Objection. Asked and
11 answered.
12 BY MR. TEIN:
13 O. --
15 : Objection. Asked and
16 answered, lack of foundation, mischaracterization
17 of her earlier testimony. She's already answered
18 that question.
19 BY MR. TEIN:
20 O. You can answer it.
21 : Same objection. It's been
22 asked and answered.
23 You can answer. I've made the objection.
24 THE WITNESS: I forget the question, now.
25
37
1 BY MR. TEIN:
2 O. Let me put it again.
3 Does it sound right to you that you told
4 that when you lied about your age to
5 Epstein,
7 : Objection. Lack of
8 foundation, asked and answered.
Page 31
EFTA00801905
-0929104.TXT
9 THE WITNESS: I could have possibly said
10 that, yes.
11 BY MR. TEIN:
12 O. You didn't want Mr. Epstein to know that
13 you were lying about your age, right?
14 A. Correct.
15 O. You didn't want Mr. Epstein to know that
16 you were not 18 yet, right?
17 A. Correct.
18 O. You wanted Mr. Epstein to believe that you
19 really were 18, right?
20 A. Correct.
21 O. Do you remember when Mr. Epstein asked
22 where you went to school?
23 A. Yes.
24 O. And you told Mr. Epstein you went to
25 , right?
38
1 A. Yes.
2 O. Was that the truth?
3 A. No.
4 O. In fact, you went to , right?
5 A. Yes.
6 O. So you lied to Mr. Epstein again, correct?
7 A. Yes.
8 O. Is the college that you told
9 Jeff's assistant that you were attending?
10 A. I don't remember having that conversation
11 with her, so I wouldn't know if that's what I said.
12 O. That was a lie, though, wasn't it?
13 : Objection to the form of the
Page 32
EFTA00801906
-0929104.TXT
14 question, lack of foundation. You're making an
15 assumption. She just answered you she can't tell
16 you that.
17 MR. TEIN: Speaking objection. And you
18 well know that,
19 : She can't answer that
20 question. The way you phrased that question,
21 you're purposely making her not be honest in her
22 testimony. She can't answer a question like that.
23 She doesn't remember. So then you say, "So you
24 were lying." That's improper and you know that.
25 That's not a proper question. And any attorney
39
1 that would do that to a witnesses or to a person
2 that's sitting in this chair is not acting
3 professionally. You can't ask a question like
4 that. You can do it, but it's not proper. And
5 I'm sure you weren't trained that way, certainly
6 not ethically.
7 MR. TEIN: Will you stop?
8 : I'm not going to stop,
9 because the way you're asking that question is
10 improper and you know it.
11 MR. TEIN: You're losing your cool.
12 BY MR. TEIN:
13 O. Ms.
14 : Trust me. I'm very calm.
15 When I lose my cool, you'll know it.
16 MR. TEIN: I do know it.
17 BY MR. TEIN:
Page 33
EFTA00801907
mmmmmaia29104.TXT
18 Q. Ms. 11111111, Mr. Epstein never asked you
19 to do anything other than massage him, correct?
20 A. Incorrect; because he asked me to take off
21 my bra, so that would be two things h
DataSet-11
Unknown
1 pages
From: Lesley Groff
Sent: Friday, April 17, 2015 7:01 PM
To: Jeffrey Epstein
Subject: Woody Dinner May 5...?
Re dinner w/Woody Allen on May 5-I show you are to fly from NY to PB on =ay 5th and the Sitrick deposition is to take
place at 10am at Jack's =ffice the same day...ls the Woody dinner to be in NY or PB?=?xml version=.0" encoding=TF-8"?>
conversation-idgkey>
118836
date-last-viewed
0
date-received
1429297274
flags
8590195717
gmail-label-ids
6
2
remote-id
498966
1
EFTA_R1_01632744
EFTA02503763
DataSet-11
Unknown
3 pages
To: Jeffrey Epsteinfieeyacation©gmail.com]
From: Richard Snyder
Sent: Tue 9/22/2009 2:55:07 PM
Subject: Re:
ok were all set. the deposition starts at 9 00 and is held about 20 min from you.we dont control
timing but i would think 2 hrs max. ill call when over and come by .looking fwd
--- On Mon, 9/21/09, Jeffrey Epstein leowcation(agmaittoin> wrote:
From: Jeffrey Epstein
Subject: Re:
To: "Richard Snyder'
Date: Monday, September 21, 2009, 7:51 PM
im four blocks south of he colony 358 el brillo
On Mon, Sep 21, 2009 at 6:43 PM, Richard Snyder
a > wrote:
agree. ill check triton and find out when he believes it will really end and where its
being held. im on a 3 35 flt home but if you think we need more time i can make a
later flt, no problem. im at the colony hotel. need your address to figure out times
best
--- On Mon, 9/21/09, Jeffrey Epstein wrote:
From: Jeffrey Epstein
Subject: Re:
To: "Richard Snyde
Date: Monday, September 21, 2009, 3:38 PM
i would like to see you alone so why dont'w we do it after depo/
On Mon, Sep 21, 2009 at 3:33 PM, Richard Snyder <
wrote:
coming in about 7 . we can have chinese at your home etc or i can come by after
deposition around 11 30
what you think
--- On Mon, 9/21/09, Jeffrey Epstein wrote:
From: Jeffrey Epstein
Subject: Re:
To: "Richard Snyder"
Date: Monday, September 21, 2009, 1:13 PM
EFTA_R1_01510044
EFTA02437270
come to see me
On Mon, Sep 21, 2009 at 12:40 PM, Richard Snyder
> wrote:
have to be in palm beach on oct 9 for a deposition arriving the night before and
having dinner with bob c. would like it very much if you care to join us
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected] and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation qmail.com and
destroy this communication and all copies thereof,
including all attachments.
EFTA_R1_01510045
EFTA02437271
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jecvacationOgmail.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA_R1_01510046
EFTA02437272
DataSet-11
Unknown
2 pages
To: Jeeyacation[[email protected]]
From: Rich Kahn
Sent: Mon 4/5/2010 4:32:53 PM
Subject: FW: payment
FYI — this was Jean Luc attorney for Deposition
Rich Kahn
HBRK Associates Inc.
301 East 66th Street, Suite 10F
New York, NY 10065
From: Dominique Nameche [mailto:[email protected]]
Sent: Friday, April 02, 2010 9:45 AM
To: Rich Kahn
Cc:
Subject: payment
Hi Rich
just to let you know payment had been send to Tama Beth Rudman
regards
Dominique Nameche
EFTA_R1_01495082
EFTA02426285
MC2 Model Management
1674 Alton Road - suite 500
Miami Beach, FL, 33139
EFTA_R1_01495083
EFTA02426286
DataSet-9
Unknown
3 pages
From: "Richard Snyder"
To: "Jeffrey Epstein"
Subject: Re:
Date: Tue, 22 Sep 2009 14:55:07 +0000
ok were all set. the deposition starts at 9 00 and is held about 20 min from you.we dont control timing but i
would think 2 hit max. ill call when over and come by .looking fwd
- - On Mon, 9/21/09, Jeffrey Epstein efrevacation@gmaiLcom> wrote:
From: Jeffrey Epstein
Subject: Re:
To: "Richard Snyder"
Date: Monday, September 21, 2009, 7:51 PM
im four blocks south of he colony 358 el brillo
On Mon, Sep 21, 2009 at 6:43 PM, Richard Snyder < > wrote:
agree. ill check criton and find out when he believes it will really end and where its being held. im on a 3 35
flt home but if you think we need more time i can make a later 41, no problem. im at the colony hotel. need
your address to figure out times best
- - On Mon, 9/21/09, Jeffrey Epstein efrevacation@gmaiLcom> wrote:
From: Jeffrey Epstein
Subject: Re:
To: "Richard Snyder"
Date: Monday, September 21, 2009, 3:38 PM
i would like to see you alone so why dont'w we do it after depo/
On Mon, Sep 21, 2009 at 3:33 PM, Richard Snyder < > wrote:
coming in about 7 . we can have chinese at your home etc or i can come by after deposition around 11
30
what you think
- - On Mon, 9/21/09, Jeffrey Epstein tevatatiot naiLcom> wrote:
From: Jeffrey Epstein
Subject: Re:
To: "Richard Snyder"
Date: Monday, September 21, 2009, 1:13 PM
come to see me..
EFTA00770370
On Mon, Sep 21, 2009 at 12:40 PM, Richard Snyder < > wrote:
have to be in palm beach on oct 9 for a deposition arriving the night before and having dinner with
bob c. would like it very much if you care to join us
***********************************************************
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments.
***********************************************************
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation®gmail.com, and
destroy this communication and all copies thereof,
including all attachments.
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
EFTA00770371
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments.
EFTA00770372
DataSet-9
Unknown
18 pages
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA037319Xra MB AB
Plaintiff;
vs.
JEFFREY EPSTEIN,
Defendant.
/PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
Detective Joseph Recary December 1, 2009 Prose Court Reporting, One
1:00 PM Clearlake Center, 250 S.
Australian Ave S, Suite 1500,
West Palm Beach, FL 33401
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was mailed this day
of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561)515-1400
(561)
B:
Spencer T. K in,
Florida Bar No: 089737
EFTA00723139
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No: 502008CA037319XXXXIVIB AB
Plaintiff,
vs. Florida Bar No:
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: Detective Joseph Recary, do Palm Beach Police Department, 345 South Country
Road, Palm Beach, Florida
YOU ARE COMMANDED to appear at PROSE COURT REPORTING, ONE
CLEARLAICE CENTER, 250 S. AUSTRALIAN AVENUE 5, SUITE 1500, WEST PALM
BEACH, FL 33401 on DECEMBER 1, 2009, at 1:00 P.M., and to have with you at that time
and place the following:
ANY AND ALL RECORDS PERTAINING TO THE JEFFREY EPSTEIN
INVESTIGATION INCLUDING BUT NOT LIMITED TO POLICE REPORTS,
PHOTOGRAPHS, LAB REPORTS, INTERNAL AND EXTERNAL MEMORANDUM
AND CORRESPONDENCE, TAPES VIDEOS, EVIDENCE AND ANY OTHER
DOCUMENTS ASSOCIATED WITH THIS CASE OR CASES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attorneys or the Court, you shall respond to this
subpoena as directed.
LEOPOLD-KUVIN, PA.
292S PGA Saoltvost. Sulk MG, PAN Ina G•rdene, Md., SUN
(561)51 14.1t (50)515-1401 (0nIAIlle)
EFTA00723140
DATED this day of October, 2009.
For the Co
By:
Kuvin, Esq.
Leopold-Kuvin, P.A.
2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
(561) 515-1400
(561) 515-1401 (facsimile)
"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in
this proceeding shall, within a reasonable time prior to any proceeding. contact the Administrative Office of the Court,
205 North Dixie Highway, Room 5.2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771
(TDD), or 1-800-955-8770 (V), via Florida Relay Service".
Dapre ako ki fa avek Americans With Disabilities Act, tout moun Id ginyin yun benven 6spesiyal you akomodasiyon
you yo patisipe nan pwogram sa-a dwt, nan yun rizonab even ninpot aranjman kapab fet, yo dwi kontakt6
Administrative Office of the Court, ki nan alma° 205 North Dixie Hils, Cham nimtro 52500 West Palm Beach,
Florida 33401 t616fon nan se (561)355-2431 oubyen 1-800-955-8771 . oubyen 1-800-955-8770 (V) an pasan pa
Florida Relay Service.
En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin d'une accommodation speciale
pour participer a ces procedures doivent, dans un temps reasonable, avant d'entreprendre aucime autre demarche,
contacter l'office administrative de la Court situe au 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le
telephone (561)355-2431 ou 1-800-955-8771 (TDD) ou 1.800.955.8770 (V) Via Florida Relay Service.
"De acuerdo con el Acto 6 Decrial) de los Americansos con impedimentos, Inhabilitados, personas en necesidad del
servicio special pare participar en este procedimiento deberin, denim de un tiempo razonable, antes de cualquier
procedimiento, ponerse en contacto con la officina Administratativa de la Corte, 205 North Dixie Highway, oficina
5.2500, West Palm Beach, FL 33401, Telefono (561) 355-2431, 1-800-955-8771 (MD) 6 1-800-955-8770 (V), Via
Florida Relay Service".
Page 2 of 2
EFTA00723141
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA037319XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: BATE AND TIME: LOCATION:
DETECTIVE December 8, 2009 Prose Court Reporting, One
MICHAEL DAWSON 9:00 AM Clearlake Center, 250 S.
Australian Ave S, Suite 1500,
West Palm Beach, FL 33401
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was mailed this2-O day
of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 515-1401
Florida Bar No: 089737
EFTA00723142
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
U Case No: 502008CA037319XXXXMB AB
Plaintiff,
vs. Florida Bar No:
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: Detective Michael Dawson, do Palm Beach Police Department, 345 South Country
Road, Palm Beach, Florida
YOU ARE COMMANDED to appear at PROSE COURT REPORTING, ONE
CLEARLAKE CENTER, 250 S. AUSTRALIAN AVENUE S, SUITE 1500, WEST PALM
BEACH, FL 33401 on DECEMBER 8, 2009, at 9:00 A.M., and to have with you at that time
and place the following:
ANY AND ALL RECORDS PERTAINING TO THE JEFFREY EPSTEIN
INVESTIGATION INCLUDING BUT NOT LIMITED TO POLICE REPORTS,
PHOTOGRAPHS, LAB REPORTS, INTERNAL AND EXTERNAL MEMORANDUM
AND CORRESPONDENCE, TAPES VIDEOS, EVIDENCE AND ANY OTHER
DOCUMENTS ASSOCIATED WITH THIS CASE OR CASES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. If you fail to:
(I) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attorneys or the Court, you shall respond to this
subpoena as directed.
LEOPOLD--KUVIN,
1PTS PGA Illettlmrd, 0dM 0M. Me Mad Gardegs. Ina. !MIS
O6O515.140k (561) $15.1401(t•W•60
EFTA00723143
DATED this S day of October, 2009.
For the Co
By:
SpeiCT' uvm, Esq.
d-Kuvin, P.A.
2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
(561) 515-1400
(561) 515-1401 (facsimile)
"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in
this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court,
205 North Dixie Highway, Room 52500, West Palm Beach, FL 33401, telephone (561)355-2431, 1400-955-8771
(TDD), or 1-800-955-8770 (V), via Florida Relay Service".
Daprd ako ki fet avek Americans With Disabilities Act, tout moun Id ginyin yun btzwen espesiyal pou akomodasiyon
pou yo patisipe nan pwogram sa-a dwe, nan yun rdzonab avan ninpot aranjman kapab fet, yo dwe kontakte
Administrative Office of the Court, ki nan nimiro 205 North Dixie Hisp=, Cham nimero 52500 West Palm Beach,
Florida 33401 tdldfon nan se (561)355-2431 oubyen 1-800-955-8771 M. oubyen 1-800-955-8770 (V) an pasan pr
Florida Relay Service.
En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin tune accommodation specials
pour participer a ces procedures doivent, dans un temps reasonable, avant dentreprendre aucune autre demarche,
contactor foffice administrative de la Court situt au 52500, 205 North Dixie Highway, West Palm Beach, FL 33401 le
telephone (561)355-2431 ou 1400-9554771 (TDD) ou 1400-9554770 (V) Via Florida Relay Service.
"De acuerdo con el Acto 6 Decreto de los Americansos con Impedknentos, Inhabilitados, personas en necesidad del
setvicio special pare pardcipar en este procedimiento deberen, denim de un tiempo razonable, antes de cualquier
procedimiento, ponerse en contacto con la officina Administratativa de la Cone, 205 North Dixie Highway, oficina
5.2500, West Palm Beach, FL 33401, Telefono (561) 355-2431, 1-800-955-8771 (TDD) 6 1.800-955.8770 (V), Via
Florida Relay Service".
Page 2 of 2
EFTA00723144
IN THE CIRCUIT COURT OF THE 15Th
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA037319XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
Detective Michelle Pagan December 8, 2009 Prose Court Reporting, One
1:00 PM Clearlake Center, 250 S.
Australian Ave S, Suite 1500,
West Palm Beach, FL 33401
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was mailed this day
of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD--KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 515-1401
B:
Spencer T. K
Florida Bar No: 089737
EFTA00723145
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
S Case No: 502008CA037319XXXXMB AB
Plaintiff,
vs. Florida Bar No:
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: Detective Michelle Pagan, do Palm Beach Police Department, 345 South Country
Road, Palm Beach, Florida
YOU ARE COMMANDED to appear at PROSE COURT REPORTING, ONE
CLEARLAKE CENTER, 250 S. AUSTRALIAN AVENUE S, SUITE 1500, WEST PALM
BEACH, FL 33401 on DECEMBER 8, 2009, at 1:00 P.M., and to have with you at that time
and place the following:
ANY AND ALL RECORDS PERTAINING TO THE JEFFREY EPSTEIN
INVESTIGATION INCLUDING BUT NOT LIMITED TO POLICE REPORTS,
PHOTOGRAPHS, LAB REPORTS, INTERNAL AND EXTERNAL MEMORANDUM
AND CORRESPONDENCE, TAPES VIDEOS, EVIDENCE AND ANY OTHER
DOCUMENTS ASSOCIATED WITH THIS CASE OR CASES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attorneys or the Court, you shall respond to this
subpoena as directed.
LEOPOLD-KU VIN, P.A.
3925 PGA 0441.4.40, 5S..104 Pals Ileaoh Goods. Florida 13110
(5411515109; (561)313.1401(besIsie)
EFTA00723146
DATED this20 day of October, 2009.
For the Co
By:
uvin, Esq.
Leopold—Kuvin, P.A.
2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
(561) 515-1400
(561) 515-1401 (facsimile)
"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in
this proceeding shall, within a reasonable time prior to any proceeding. contact the Administrative Office of the Court,
205 North Dixie Highway, Room 52500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771
(TDD), or 1-800-955-8770 (V), via Florida Relay Service".
Dare ako ki fa avek Americans With Disabilities Act, tout moon Id ginyin yon bezwen dspesiyal you akomodasi)vn
Administrative Office of the Court, Id nan nimero 205 North Dixie
Florida 33401 telefon nan se (561)355-2431 oubyen 1-800-955-8771
luta,
pou yo patisipe Mn pwognun sa-a dyed, min yun rtzonab avan ninpot aranjman kapab fet, yo dwd kontalctd
Chain nimero 5.2500 West Palm Beach,
oubyen 1-800-955-8770 (V) an pasan pa
Florida Relay Service.
En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin dune accommodation speciale
pour participer a ces procedures doivent, dans un temps raisonable, avant d'entreprendre aucune autre demarche,
contaaer l'office administrative de la Court situ& au 52500, 205 North Dixie Highway, West Palm Beach, FL 33401 le
telephone (561)355-2431 ou 1-800-955-8771 (TDD) ou 1-800-955-8770 (V) Via Florida Relay Service.
"De acuerdo con el Acto 6 Decreto de los Americansos con linpedimentos, lnhabilitados, personas en necesidad del
servicio special para participar en este procedimiento deberan, dentro de un tiempo razonable, antes de cualquier
procedimiento, ponerse en contacto can la officina Administratativa de la Cone, 205 North Dixie Highway, &wine
52500, West Palm Beach, FL 33401, Telefono (561) 355-2431, 1-800-955-8771 (TDD) 6 1-800-955-8770 (V), Via
Florida Relay Service".
Page 2 of 2
EFTA00723147
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA037319XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
ROBERT MEISTER December 14, 2009 Prose Court Reporting, One
9:00 AM Clearlake Center, 250 S.
Australian Ave S, Suite 1500,
West Palm Beach, FL 33401
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or arc being taken for such
other purposes as are permitted under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was mailed this2O day
of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561)515-14 1
By:
Spencer T. Kuv
Florida Bar No: 089737
EFTA00723148
IN THE CIRCUIT COURT OF THE 1511I
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No: 502008CA037319XXXXMB AB
Plaintiff,
vs. Florida Bar No:
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: Robert Meister, 101 Seminole Avenue, Palm Beach, FL 33480
YOU ARE COMMANDED to appear at PROSE COURT REPORTING, ONE
CLEARLAKE CENTER, 250 S. AUSTRALIAN AVENUE 5, SUITE 1500, WEST PALM
BEACH, FL 33401 on DECEMBER 14, 2009, at 9:00 A.M., and to have with you at that time
and place the following:
ANY AND ALL RECORDS PERTAINING TO THE JEFFREY EPSTEIN
INVESTIGATION INCLUDING BUT NOT LIMITED TO POLICE REPORTS,
PHOTOGRAPHS, LAB REPORTS, INTERNAL AND EXTERNAL MEMORANDUM
AND CORRESPONDENCE, TAPES VIDEOS, EVIDENCE AND ANY OTHER
DOCUMENTS ASSOCIATED WITH THIS CASE OR CASES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attorneys or the Court, you shall respond to this
subpoena as directed.
DATED this 2.O day of October, 2009.
LEOPOLD-KU YIN, put
345 PGA 114Seavd, $44 200. Pala 1k0c0 Gontas.10•416 SMIO
(561)515440; (561) 5134401(lies140
EFTA00723149
For the Co
By:
vin, Esq.
Leopold—Kuvin, P.A.
2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
(561) 515-1400
(561) 515-1401 (facsimile)
"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in
this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court,
205 North Dixie Highway, Room 5.2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771
(TDD), or 1-800-955-8770 (V), via Florida Relay Service".
Daprt ako Id fet avek Americans With Disabilities Act, tout moun Id ginyin yun bezwen espesiyal pou akomodasiyon
pou yo patisipe nan pwogram sa-a dime, nan yun itzonab avan ninpot aranjman kapab fa, yo dwe kontakte
Administrative Office of the Court, ki nan nimdro 205 North Dixie Hat Chem nimdro 5.2500 West Palm Beach,
Florida 33401 edition nan se (561)355-2431 oubyen 1-800-955-8771 oubyen 1-800-955-8770 (V) an pasan pa
Florida Relay Service.
En accordance awe la Loi des "Americans With Disabilities". Les pasormes en besoin d'une accommodation speciale
pour participer a eta procedures doivent, dans un temps raisonable, avant d'entreprendrc aucune attire demarche,
ender roffice administrative de la Court sink au 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le
telephone (561)355-2431 ou 1400-955-8771 (TDD) ou 1-800-955-8770 (V) Via Florida Relay Service.
"De acuerdo con el Acto 6 Decreto de los Americansos con Impedimentos, Inhabilitados, personas en necesidad del
servicio special pare participar en este procedimiento deberan, denim de un tiempo razonable, antes de cualquier
procedimiento, ponase en contacto con la officina Administratativa de la Corte, 205 North Dixie Highway, oficha
52500, West Palm Beach, FL 33401, Telefono (561) 355-2431, 1-800-955-8771 (TDD) 6 1-800-955-8770 (V), Via
Florida Relay Service".
Page 2 of 2
EFTA00723150
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
• Plaintiff,
Case No: 502008CA037319XXXX MB AB
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: DATE AND TIME: LOCATION:
TODD MEISTER December 14, 2009 Prose Court Reporting, One
1:00 PM Clearlake Center, 250 S.
Australian Ave S, Suite 1500,
West Palm Beach, FL 33401
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was mailed this 20 day
of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN,
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 515-
Spencer T. Kuvin, Esq.
Florida Bar No: 089737
EFTA00723151
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
U Case No: 502008CA037319XXXXMB AB
Plaintiff,
vs. Florida Bar No:
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: Todd Meister, 101 Seminole Avenue, Palm Beach, FL 33480
YOU ARE COMMANDED to appear at PROSE COURT REPORTING, ONE
CLEARLAKE CENTER, 250 S. AUSTRALIAN AVENUE S, SUITE 1500, WEST PALM
BEACH, FL 33401 on DECEMBER 14, 2009, at 1:00 P.M., and to have with you at that time
and place the following:
ANY AND ALL RECORDS PERTAINING TO THE JEFFREY EPSTEIN
INVESTIGATION INCLUDING BUT NOT LIMITED TO POLICE REPORTS,
PHOTOGRAPHS, LAB REPORTS, INTERNAL AND EXTERNAL MEMORANDUM
AND CORRESPONDENCE, TAPES VIDEOS, EVIDENCE AND ANY OTHER
DOCUMENTS ASSOCIATED WITH THIS CASE OR CASES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. If you fail to:
(1) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attorneys or the Court, you shall respond to this
subpoena as directed.
DATED this 2.Oday of October, 2009.
LEOPOLD4CUVIN, P.A.
292.5 PGA lk.lerant. Smile ZOO. Not lath Grim. Florida MP)
4541)313.100: WI> 81$.1102 (fbah•A)
EFTA00723152
For the Court
By:
. uvin, Esq.
ld-.Kuvin, PA.
2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
(561) 515-1400
(561) 515-1401 (facsimile)
"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in
this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court,
205 North Dixie Highway, Room 5.2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771
(TDD), or 1-800-955-8770 (V), via Florida Relay Service".
Dapre ako ki fet avek Americans With Disabilities Act, tout moan ki ginyin yun bdzwen espesiyal you akomodasiyon
you yo pafisipe nan pwogram sa-a dw₹, min yun rdzonab avan ninpot aranjman kapab fet, yo dwe kontalcte
Administrative Office of the Court, Id nan !tinier° 205 North Dixie FIribuy, Chant nimero 52500 West Palm Beach,
Florida 33401 telefon nan sd (561)355-2431 oubyen 1-800-955-8771 IM. oubyen 1-800-955-8770 (V) an pasan pa
Florida Relay Service.
En accordance avec la Loi des "Americans With Disabilities". Les personnes en bcsoin dime accommodation spociale
pour participer a ces procedures doivent, dans 1112 temps reasonable, avant d'entreprendre aucune autre d₹marche,
contacter roll-Ice administrative de la Court shoe au 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le
telephone (561)355-2431 ou 1.800.955-8771 (TDD) ou 1.800.955-8770 (V) Via Florida Relay Service.
"De acuerdo con el Aao 6 Decreto de los Americansos con Impedimentos, Inhabilitados, personas en neccsidad del
servicio special pwa participar en este procedirniento deberan, dentro de tm tiempo rananable, antes de cualquier
procedimiento, ponerse en contacto con la officina Administratativa de la Corte, 205 North Dixie Highway, oficina
52500, West Palm Beach, FL 33401, Telefono (561) 355-2431, 1-800-955.8771 (TDD) 6 1-800-955-8770 (V), Via
Florida Relay Service".
Page 2 of 2
EFTA00723153
IN THE CIRCUIT COURT OF THE 15Th
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA037319)OOOC MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
NAME: SATE AND TIME: LOCATION:
RECORDS CUSTODIAN December 1, 2009 Prose Court Reporting, One
PALM BEACH COUNTY 9:00 AM Clearlake Center, 250 S.
POLICE DEPARTMENT Australian Ave S, Suite 1500,
West Palm Beach, FL 33401
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of Florida. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
I HEREBY CERTIFY that a true and correct copy of this Notice was mailed this day
of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303 Banyon Boulevard, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD--KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
(561) 515-1400
(561) 515-1401
By:
pencer T.
Florida Bar No: 0
EFTA00723154
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
U Case No: 502008CA037319XXXXMB AB
Plaintiff,
vs. Florida Bar No:
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S SUBPOENA FOR VIDEOTAPED DEPOSITION DUCES TECUM
THE STATE OF FLORIDA:
TO: Records Custodian, Palm Beach County Police Department, 345 South Country
Road, Palm Beach, Florida
YOU ARE COMMANDED to appear at PROSE COURT REPORTING, ONE
CLEARLAKE CENTER, 250 S. AUSTRALIAN AVENUE S, SUITE 1500, WEST PALM
BEACH, FL 33401 on DECEMBER 1, 2009, at 9:00 A.M. , and to have with you at that time
and place the following:
ANY AND ALL RECORDS PERTAINING TO THE JEFFREY EPSTEIN
INVESTIGATION INCLUDING BUT NOT LIMITED TO POLICE REPORTS,
PHOTOGRAPHS, LAB REPORTS, INTERNAL AND EXTERNAL MEMORANDUM
AND CORRESPONDENCE, TAPES VIDEOS, EVIDENCE AND ANY OTHER
DOCUMENTS ASSOCIATED WITH THIS CASE OR CASES.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. If you fail to:
(I) appear as specified; or
(2) furnish the records instead of appearing as provided above; or
(3) object to this subpoena,
you may be in contempt of Court. You are subpoenaed to appear by the following attorneys, and
unless excused from this subpoena by these attorneys or the Court, you shall respond to this
subpoena as directed.
LEOPOLD-KUV1N,
DM PGA 13001mrd, ten 200. POO Stub Guts. MA& 13110
(SW) 513.1400; WO1114M 111411111110
EFTA00723155
DATED this2 day of October, 2009.
For the Co
By:
in, Esq.
Leopold—Kuvin, P.A.
2925 PGA Boulevard
Suite 200
Palm Beach Gardens, Florida 33410
(561) 515-1400
(561) 515-1401 (facsimile)
"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in
this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court,
205 North Dixie Highway, Room 5.2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771
(TDD), or 1-800-955-8770 (V), via Florida Relay Service".
Dapre ako ki fet avek Americans With Disabilities Act, tout moun ki ginyin yun bdzwen Espesiyal pou alcomodasiyon
pou yo patisipe nan pwogram sa-a dwe, nan ytm rezonab avan ninpot aranjman kapab fet, yo dwe kontakte
Administrative Office of the Court, ki nan nimdro 205 North Dixie Highway, Cham Miner° 52500 West Palm Beach,
Florida 33401 Melon nan se (561)355.2431 oubyen 1.800.955-8771 oubyen I-800-955-4770 (V) en pasan pa
Florida Relay Service.
En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin dune accommodation speciak
pour participer a ces procedures doivent, dans un temps raisonable, avant denhvpras4.. amine autre ddmarche,
contactor I'office administrative de Is Court shire au 52500, 205 North Dixie Highway, West Palm Beach, FL 33401 le
telephone (561)355-2431 ou 1-800-955-8771 (TDD) ou I-800-955-8770 (V) Via Florida Relay Service.
"De acuerdo con el Acto 6 Decreto de los Americansos con Impedimentos, Inhabilitados, personas en necesidad del
servicio special pare participar en este procedimiento deberan, denim de un tiempo razonable, antes de cualquier
procedimiento, ponerse en contacto con la officina Administratativa de la Corte, 205 North Dixie Highway, oficina
5.2500, West Palm Beach, FL 33401, Telefono (561) 355-2431, I-800-955-8771 (TDD) 6 1-800-955-8770 (V), Via
Florida Relay Service.
Page 2 of 2
EFTA00723156
DataSet-9
Unknown
5 pages
IN THE CIRCUIT COURT OF THE 15th
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO: 502008CA028051)00(XMB AB
i.
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
SECOND RE-NOTICE OF VIDEO DEPOSITION OF JEFFREY EPSTEIN
(CHANGE OF TIME PER DEFENDANT'S REQUEST1
PLEASE TAKE NOTICE that the attorney for the plaintiff in the above-
styled cause will take the video deposition of Jeffrey Epstein on February 17,
2010 at 11:00 a.m. for the purposes of discovery at the following location:
US Legal Support
444 West Railroad Avenue
Suite 300
West Palm Beach, FL 33401
581-835-0220
Said deposition will be taken before US Legal Support Reporting Agency,
a Notary Public or any officer authorized to administer oaths by the laws of the
State of Florida, and a person who is neither a relative, nor employee, nor
attorney, nor counsel of any of the parties and who is neither a relative nor
employee of such attorney or counsel, and who is not financially interested in the
action.
Said deposition will be taken pursuant to Florida Rules of Civil Procedure
in such cases provided. Said oral examination will continue from hour to hour
and from day to day until completed.
EFTA00606747
CERTICATE OF SERVICE
I HEREBY CERTIFY that the original of the above and a copy of the
foregoing has been on February \O , 2010 via U.S. Mail and email transmittal
to all those on the attached service list
Farmer, Jaffe, Welssing,
Edwards, Fistos & Lehrman, ■
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954) 524-2820
• (954) 524-2822 fax
[email protected]
By:
BRADLEY J. EDWARDS
Florida Bar No.: 542075
cc: US Legal (via email)
SERVICE LIST
Robert D. Critton, Jr.
BURMAN, CRITTON, et al.
303 Banyan Boulevard, Suite 400
West Palm Beach, FL 33401
Jay Howell, Esq.
Jay Howell & Assoc.
644 Cesery Boulevard
Suite 250
Jacksonville, FL 32211
Jack Alan Goldberger, Esq.
Atterbury Goldberger et al.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401
EFTA00606748
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE, CASE NO. 08-CV-80893-CIV-MARFtNJOHNSON
Plaintiff,
Vs.
JEFFREY EPSTEIN, et al.
Defendant.
Related Cases:
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE that plaintiff, Jane Doe, will take the video deposition by
oral examination, of the persons named below, at the time, on the date, at the hour of
the place indicated:
NAME DATE AND PLACE OF TAKING DEPOSITON
TIME
March 24, 2010 Prose Court Reporting
c/o Bruce Reinhart 10:00 AM One Clearlake Centre
Bruce E. Reinhart, P.A. 250 South Australian Avenue,
250 Australian Avenue South, Suite 1500
Suite 1400 West Palm Beach, FL 33401
West Palm Beach, FL 33401
upon oral examination before Prose Court Reporting, Notary Public, or any other notary
public or officer authorized by law to take depositions In the State of Florida. The oral
EFTA00606749
CASE NO: 08-CV-80119.14ARRAIJOHNSON
examination will continue from day to day until completed. The depositions are being
taken for the purpose of discovery, for use at trial, or for such other purposes as are
permitted under the Rules of Court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing was served by e-mail on February
12, 2010 to: See attached service list.
Bradley J. Edwards
Farmer, Jaffe, Weissing,
Edwards, Fistos & Lehrman, PL
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954) 524-2820
(954) 524-2822 fax
[email protected]
By: cW2
BRADLEY J. EDWARDS
Florida Bar No.: 542075
2
EFTA00606750
CASE NO: 08-CV-80119-14ARRAJJOHNSON
SERVICE LIST
Jane Doe v. Jeffrey Epstein
United States District Court - Southern District of Florida
Jack Alan Goldberger, Esq.
[email protected]
Robert D. Critton, Esq.
rcrittoneklclaw.com
Isidro Manual Garcia
isidroaarciaebellsouth.net
Jack Patrick Hill
inhaisearcvlaw.com
Katherine Warthen Ezeil
[email protected]
Michael James Pike
[email protected]
Paul G. Cassell
casselloabc1claw.com
Richard Horace Willits
lawverswillitseaolcom
Robert C. Josefsberg
riosefsberagDoodhurst.com
Adam D. Horowitz
ahorowitzOsexabuseattornev.com
Stuart S. Mermeistein
ssm©sexabuseattornev.com
3
EFTA00606751
DataSet-9
Unknown
36 pages
0172
1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
2
CASE No. 502008CA037319XXXXMB AB
3
4
5 =-1
6 Plaintiff,
7
- Vs-
9 JEFFREY EPSTEIN,
10 Defendant.
11
12
13 CONTINUED DEPOSITION OF JEFFREY EPSTEIN
14 VOLUME III
15
16 Thursday, October 8, 2009
17
18 1:46 - 3:48 p.m.
19
20 250 South Australian Avenue
Suite 1400
21 West Palm Beach,Florida 33401
22
23 Reported By:
Jeana Ricciuti, RPR, FPR, CLR
24 Notary Public, State of Florida
Prose Court Reporting Agency, Inc.
25
0173
1 APPEARANCES:
2 On behalf of the Plaintiff:
SPENCER T. KUVIN, ESQUIRE
3 ADAM LANGINO, ESQUIRE
LEOPOLD KUVIN, P.A.
4 2295 PGA Boulevard
Suite 200
5 Palm Beach Gardens, Florida 33410
Phone:
6
On behalf of §§§. and III. and Jane Doe in Case No.
7 80893:
CARA L. HOLMES, ESQUIRE
8 ROTHSTEIN, ROSENFELDT & ADLER
401 East Las Olas Boulevard
9 Suite 1650
Fort Lauderdale, Florida 33301
10 Phone:
11 On behalf of Plaintiff Jane Doe in Case No. 80591 and
80656 via telephone:
12 KATHERINE W. EZELL, ESQUIRE
PODHURST ORSECK, P.A.
13 25 West Flagler Street
Miami, Florida 33130
14 Phone:
15 On behalf of the Defendant:
JACK GOLDBERGER, ESQUIRE
16 STORY KOWLES, PARALEGAL
ATTERBURY, GOLDBERGER & WEISS, P.A.
EFTA01158588
17 250 South Australian Avenue
Suite 1400
18 West Palm Beach, Florida 33401
Phone:
19
MICHAEL J. PIKE, ESQUIRE
20 BURMAN, CRITTON, LUTTIER & COLEMAN, P.A.
303 Banyan Boulevard
21 Suite 400
West Palm Beach, Florida 33401
22 Phone:
23 ALSO PRESENT:
24 DAN DOSKEY, VIDEOGRAPHER
VISUAL EVIDENCE, INC.
25
0174
1
EXHIBITS
2
3 WITNESS: CONT'D DIRECT
4 JEFFREY EPSTEIN
5 BY MR. KUVIN 175
6
7
8
EXHIBITS
9 - - - -
10 NUMBER DESCRIPTION PAGE
11 PLAINTIFF'S EX. 9 PHOTOGRAPH OF GHISLAINE 182
MAXWELL
12 PLAINTIFF'S EX. 10 PHOTOGRAPH OF JOANNA 191
SHOGERT
13 PLAINTIFF'S EX. 11 PHOTOGRAPH OF EULA MAXWELL 196
PLAINTIFF'S EX. 12 PHOTOGRAPH 198
14 PLAINTIFF'S EX. 13 PHOTOGRAPH OF 199
PLAINTIFF'S EX. 14 PHOTOGRAPH OF
PLAINTIFF'S EX. 15 PHOTOGRAPH OF 201
16 PLAINTIFF'S EX. 16 PHOTOGRAPH OF PRINCE 201
ANDREW
17 PLAINTIFF'S EX. 17 LETTER TO B. KRISCHER FROM 203
M. REITER
18 PLAINTIFF'S EX. 18 RECEIPT OF PURCHASES MADE 206
FROM JAIL
19 PLAINTIFF'S EX. 19 FAA REGISTRY 218
20
21
22
23
24
25
0175
1 PROCEEDINGS
2 - - -
3 THE VIDEOGRAPHER: We're back on the record at
4 1:46.
5 CONTINUED DIRECT EXAMINATION
6 BY MR. KUVIN:
7 Q. Do you personally know John Mack, former CEO
8 at Morgan Stanley?
9 A. I'll have to answer that the same way I've
10 answered most of your questions here today, Mr. Kuvin,
11 which is, I intend to respond to all relevant questions
EFTA01158589
12 regarding this lawsuit; however, at the present time, my
13 attorneys have counseled me I cannot provide answers to
14 any questions relevant to this lawsuit. I must accept
15 this advice or risk losing my 6th Amendment right to
16 effective representation. Accordingly, I assert my
17 federal constitutional rights as guaranteed by the 5th,
18 6th and 14th Amendment to the United States
19 Constitution.
20 MR. KUVIN: Okay. Same deposition as shown
21 before, different clip. I'm going to play it for
22 counsel first.
23 MR. PIKE: Thank you.
24 MR. KUVIN: Mr. Videographer, just let me know
25 when you're ready.
0176
1 THE VIDEOGRAPHER: Whenever you are.
2 MR. KUVIN: Okay.
3 (Video played.)
4 VIDEO WITNESS: "What did I do to Jeffrey and
5 what did Jeffrey do to me? I went up there
6 multiple times; I can't count. And I would be on a
7 massage table, massaging his legs, he would turn
8 over, his penis would be hanging out. He would put
9 a vagina -- or a vibrator to my vagina. He would
10 touch my vagina with his fingers. He would touch
11 my breasts. He would try to kiss my mouth. He
12 would bring my hands toward his penis."
13 (Video stopped.)
14 MR. KUVIN: Okay.
15 MR. PIKE: I'm just going to object to the use
16 of the video as to relevance, predicate and
17 foundation.
18 BY MR. KUVIN:
19 Q. All right. Let me get it back to the same
20 location.
21 Sir, first of all, once again, just so I can
22 lay the foundation for this, do you recognize this girl?
23 A. I'm going to have to respond to that question
24 the same way I've responded to most of your other
25 questions here today, which is, I intend to respond to
0177
1 all relevant cannot provide answers to any questions
2 relevant to this lawsuit; however, at the present time,
3 my attorneys have counseled me I cannot provide answers
4 to any questions relevant to the lawsuit. I must accept
5 this advice or risk losing my 6th Amendment right to
6 effective representation. Accordingly, I assert my
7 federal constitutional rights as guaranteed by the 5th,
a 6th and 14th Amendment to the United States
9 Constitution.
10 Q. Did this girl bring §§§. to your home for a
11 naked massage?
12 A. I'm going to have to respond to that the same
13 way I've responded to most of your other questions here
14 today, which is, I intend to respond to all relevant
15 questions regarding this lawsuit; however, at the
16 present time, my attorneys have counseled me I cannot
17 provide answers to any questions that may be relevant to
18 the lawsuit. I must accept this advice or risk losing
19 my 6th Amendment right to effective representation.
20 Accordingly, I assert my federal constitutional rights
21 as guaranteed by the 5th, 6th and 14th Amendment to the
22 United States Constitution.
EFTA01158590
23 Q. I'd like to play this clip for you and then
24 I'm going to ask you a question.
25 MR. PIKE: The same clip you just played?
0178
1 MR. KUVIN: Exactly.
2 MR. PIKE: Same objection.
3 (Video played.)
4 VIDEO WITNESS: "What did I do to Jeffrey and
5 what did Jeffrey do to me? I went out there
6 multiple times; I can't count. And I would be on a
7 massage table, massaging his legs. He would turn
8 over, his penis would be hanging out. He would put
9 a vagina -- or vibrator to my vagina. He would
10 touch my vagina with his fingers. He would touch
11 my breasts. He would try to kiss my mouth. He
12 would bring my hands toward his penis."
13 (Video stopped.)
14 BY MR. KUVIN:
15 Q. Did you do that with that girl?
16 MR. PIKE: Form.
17 THE WITNESS: I intend to respond to all
18 relevant questions regarding this lawsuit; however,
19 at the present time, my attorneys have counseled me
20 I cannot provide answers to any questions that may
21 be relevant to this lawsuit. I must accept this
22 advice or risk losing my 6th Amendment right to
23 effective representation. Accordingly, I must
24 assert my federal constitutional rights as
25 guaranteed by the 5th, 6th and 14th Amendment to
0179
1 the United States Constitution.
2 BY MR. KUVIN:
3 Q. Did you do what that young lady described just
4 now to hundreds of women, including III.?
5 MR. PIKE: Form, argumentative, harassing,
6 lacks appropriate predicate, foundation, lacks
7 identity.
8 THE WITNESS: Excuse me. I'm going to respond
9 to that the same way I've responded to most of your
10 other questions here today, which is, I intend to
11 respond to all relevant questions regarding this
12 lawsuit; however, at the present time, my attorneys
13 have counseled me that I cannot provide answers to
14 any questions relevant to the lawsuit. I must
15 accept their advice or risk losing my 6th Amendment
16 right to effective representation. Accordingly, I
17 must assert my federal constitutional rights as
18 guaranteed by the 5th, 6th and 14th Amendment to
19 the United States Constitution.
20 BY MR. KUVIN:
21 Q. While §§§. was standing naked in your home,
22 specifically in your bathroom, did you tell her that you
23 could get her an interview as a model because of your
24 connections?
25 A. I'm going respond to that the same way I've
0180
1 responded to most of your questions today, Spencer. I
2 intend to respond to all relevant questions regarding
3 this lawsuit; however, at the present time, my attorneys
4 have counseled me I cannot provide answers to any
5 questions that may be relevant to the lawsuit. I must
6 accept this advice or risk losing my 6th Amendment right
7 to effective representation. Accordingly, I must assert
EFTA01158591
8 my federal constitutional right as guaranteed by the
9 5th, 6th and 14th Amendment to the United States
10 Constitution.
11 MR. PIKE: Same objection to that line of
12 questioning.
13 BY MR. KUVIN:
14 Q. As §§§. was standing naked in your bathroom
15 before you when she was 15, did you ask her to turn
16 around so you could see her ass better?
17 MR. PIKE: Form, argumentative, harassing,
18 lacks appropriate predicate, foundation.
19 THE WITNESS: I'll respond to that as I
20 responded to your last question, which is, I intend
21 to respond to all relevant questions regarding this
22 lawsuit; however, at the present time, my attorneys
23 have counseled me I cannot provide answers to any
24 questions that may be relevant to this lawsuit. I
25 must accept their advice or risk losing my 6th
0181
1 Amendment right to effective representation;
2 therefore, I must assert my federal constitutional
3 rights as guaranteed by the 5th, 6th and 14th
4 Amendment to the United States Constitution.
5 BY MR. KUVIN:
6 Q. When III. was 15 years old and standing naked
7 in front of you in your bathroom, did you tell her that
8 you could help her become a model?
9 MR. PIKE: Same objections, including
10 foundation.
11 THE WITNESS: Is it different than the last
12 question?
13 MR. KUVIN: Uh-huh.
14 MR. GOLDBERGER: Just go ahead.
15 THE WITNESS: Okay. I intend to respond to
16 all relevant questions pertaining to this lawsuit;
17 however, at the present time, my attorneys have
18 counseled me I cannot provide answers to any
19 questions that may be relevant to this lawsuit, so
20 I've answered most questions here today the same
21 way. I must expect that -- accept their advice or
22 risk losing my 6th Amendment right to effective
23 representation. Accordingly, I assert my federal
24 constitutional rights as guaranteed by the 5th, 6th
25 and 14th Amendment to the United States
0182
1 Constitution.
2 BY MR. KUVIN:
3 Q. Who is Ghislaine Maxwell?
4 A. I intend to respond to all relevant questions
5 regarding this lawsuit; however, at the present time, my
6 attorneys have counseled me that I cannot provide
7 answers to any questions relevant to this lawsuit. As I
8 have done to most of your other questions here today, I
9 must accept their advice or risk losing my 6th Amendment
10 right to effective representation. Accordingly, I
11 assert my federal constitutional rights as guaranteed by
12 the 5th, 6th and 14th Amendment to the United States
13 Constitution.
14 MR. KUVIN: Let me show the camera what we'll
15 mark as Exhibit 9 to this deposition.
16 THE VIDEOGRAPHER: Okay.
17 (Plaintiff's Exhibit No. 9 was marked for
18 identification.)
EFTA01158592
19 BY MR. KUVIN:
20 Q. Let me show you what we've marked as Exhibit 9
21 to your deposition. Do you recognize Ghislaine Maxwell
22 in this photograph?
23 A. Yes.
24 Q. And who is she standing with?
25 A. Her father.
0183
1 Q. And her father is Robert Maxwell?
2 A. Was Robert Maxwell.
3 Q. I'm sorry, he's passed, correct?
4 A. Correct.
5 Q. She is a close friend of yours, is she not?
6 A. I'm going to respond to that question the same
7 way I've responded to most of your other questions here
8 today, Mr. Kuvin, which is, I intend to respond to all
9 relevant questions regarding to this lawsuit; however,
10 at the present time, my attorneys have counseled me I
11 cannot provide answers to any questions that may be
12 relevant to this lawsuit. I must expect -- accept their
13 advice or risk losing my 6th Amendment right to
14 effective representation. Accordingly, I must assert my
15 federal constitutional rights as guaranteed by the 5th,
16 6th and 14th Amendment to the United States
17 Constitution.
18 Q. Ghislaine Maxwell has accompanied you to
19 numerous social events in the last few years; isn't that
20 true?
21 MR. PIKE: Form.
22 THE WITNESS: I'm going to respond to that
23 question the same way I've responded to most of
24 your questions here today, which is, I intend to
25 respond to all relevant questions regarding your
0184
1 lawsuit; however, at the present time, my attorneys
2 have counseled me I cannot provide answers to any
3 questions that may be relevant to that lawsuit. I
4 must accept their advice or risk losing my 6th
5 Amendment right to effective representation.
6 Accordingly, I must assert my federal
7 constitutional right as guaranteed by the 5th, 6th
8 and 14th Amendment of the United States
9 Constitution.
10 BY MR. KUVIN:
11 Q. One of your houseboys that has been deposed in
12 this case testified that you were a rather nice
13 gentleman that used to talk to the staff, and that when
14 Ms. Maxwell came into the picture, that you stopped
15 talking to the staff and the staff had to communicate
16 through Ms. Maxwell. Do you agree or disagree with
17 that?
18 MR. PIKE: Form, foundation, predicate,
19 argumentative, assumes facts not in evidence.
20 THE WITNESS: I'm going to answer that the
21 same way I've answered most of your questions here
22 today, which is, I intend to respond to all
23 relevant questions regarding this lawsuit; however,
24 at the present time, my attorneys have counseled me
25 that I cannot provide answers to any questions that
0185
1 may be relevant to your lawsuit. I must accept
2 their advice or risk losing my 6th Amendment right
3 to effective representation. Accordingly, I assert
EFTA01158593
4 my federal constitutional rights as guaranteed by
5 the 5th, 6th and 14th Amendment of the United
6 States Constitution.
7 BY MR. KUVIN:
8 Q. He also testified that he felt you were a
9 rather normal guy until Ms. Maxwell came into the
10 picture, and that she led you into this life of
11 perversion, sexual perversion. Do you agree with that?
12 MR. PIKE: Same objections.
13 THE WITNESS: I'm going to respond to that the
14 same way I've responded to most of your questions
15 here today, Mr. Kuvin, which is, I intend to
16 respond to all relevant questions regarding this
17 lawsuit; however, at the present time, my attorneys
18 have counseled me I cannot provide answers to any
19 questions relevant to this lawsuit. I must accept
20 their advice or risk losing my 6th Amendment --
21 excuse me -- I must accept their advice or risk
22 losing my 6th Amendment right to effective
23 representation. Accordingly, I must assert my
24 federal constitutional rights as guaranteed by the
25 5th, 6th and 14th Amendment to the United States
0186
1 Constitution.
2 BY MR. KUVIN:
3 Q. Did Ms. Maxwell procure underaged girls for
4 you to have sexual relationships with?
5 A. I'm going to answer that question the same way
6 I've answered most of your other questions today,
7 Mr. Kuvin, which is, I intend to respond to all relevant
8 questions regarding this lawsuit; however, at the
9 present time, my attorneys have counseled me I cannot
10 provide answers to any questions relevant to that
11 lawsuit. Excuse me. I must accept their advice or risk
12 losing my 6th Amendment right to effective
13 representation. Accordingly, I must assert my federal
14 constitutional rights as guaranteed -- guaranteed by the
15 5th, 6th and 14th Amendments to the United States
16 Constitution.
17 Q. Ms. Maxwell procured a particular underaged
18 girl who worked at Donald Trump's Maralago, for you to
19 have a sexual relationship with; isn't that true?
20 MR. PIKE: Form, argumentative, lacks
21 appropriate predicate, foundation, assumes facts
22 not in evidence.
23 THE WITNESS: I'm going to respond to that the
24 same way I've responded to most of your other
25 questions here today, Mr. Kuvin, which is, I intend
0187
1 to respond to all relevant questions regarding this
2 lawsuit; however, at the present time, my attorneys
3 have counseled me I cannot provide answers to any
4 questions relevant to that lawsuit. I must accept
5 their advice or risk losing my 6th Amendment right
6 to effective representation. Therefore, I assert
7 my federal constitutional rights as guaranteed by
8 the 5th, 6th and 14th Amendments to the United
9 States Constitution.
10 BY MR. KUVIN:
11 Q. Do you know where Donald Trump's Maralago
12 estate is?
13 A. Yes.
14 Q. Have you been there?
EFTA01158594
15 A. Yes.
16 Q. Who with?
17 A. I'm going to have to answer that question the
18 same way I've answered most of your other questions here
19 today. I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me I cannot provide answers to
22 any questions that may be relevant to the same lawsuit.
23 I must accept their advice or risk losing my 6th
24 Amendment right to effective representation.
25 Accordingly, I must assert my federal constitutional
0188
1 rights as guaranteed by the 5th, 6th and 14th Amendment
2 to the United States Constitution.
3 Q. Have you seen the high school transcripts
4 grades of girls that you have had sexual relationships
5 with dating back to 2005?
6 MR. PIKE: Form, relevance, improper
7 hypothetical, lacks facts -- assumes facts not in
8 evidence, lacks appropriate predicate, foundation.
9 THE WITNESS: I'm going to answer that
10 question the same as I've answered most of your
11 other questions here today, Mr. Kuvin, which is, I
12 intend to respond to all relevant questions
13 regarding this lawsuit; however, at the present
14 time, my attorneys have counseled me that I cannot
15 provide answers to any questions that may be
16 relevant to this lawsuit. I must accept their
17 advice or risk losing my 6th Amendment right to
18 effective representation. Accordingly, I assert my
19 federal constitutional rights as guaranteed by the
20 5th, 6th and 14th Amendment to the United States
21 Constitution.
22 BY MR. KUVIN:
23 Q. Do you deny that the high school transcripts
24 which were found in your trash on Palm Beach that showed
25 the ages of some of the girls you were engaged with
0189
1 sexual acts with at your home came from your house?
2 MR. PIKE: Same objection in addition to
3 argumentative and harassing.
4 THE WITNESS: I intend to respond to all
5 relevant questions regarding this lawsuit; however,
6 as I've done with most of your other questions
7 today, at the present time my attorneys have
8 counseled me that I cannot provide answers to any
9 of those questions relevant to this lawsuit. I
10 must accept their advice or risk losing my 6th
11 Amendment right to effective representation.
12 Accordingly, I must assert my federal
13 constitutional rights as guaranteed by the 5th, 6th
14 and 14th Amendments to the United States
15 Constitution.
16 BY MR. KUVIN:
17 Q. Did you have numerous photos of nude young
18 women, girls under the age of 18, back in your home
19 in -- on Palm Beach Island in 2005 and 2006?
20 A. I'm going to have to respond to that question
21 the same way I've responded to most of your questions
22 here today, which is, I intend to respond to all
23 relevant questions regarding this lawsuit; however, at
24 the present time, my attorneys have counseled me I
25 cannot provide answers to any questions relevant to the
EFTA01158595
0190
1 same lawsuit. I must accept their advice or risk losing
2 my 6th Amendment right to effective representation.
3 Accordingly, I must assert my federal constitutional
4 rights as guaranteed by the 5th, 6th and 14th Amendment.
5 Q. Did you have photographs of girls under the
6 age of ten who were nude, either partially or fully
7 nude, in your home on Palm Beach in 2005 and 2006?
8 MR. PIKE: Form.
9 THE WITNESS: I'm going to respond to that
10 question the same way I've responded to most of
11 your other questions, which is, I intend to respond
12 to all relevant questions regarding this lawsuit;
13 however, at the present time, my attorneys have
14 counseled me I cannot provide answers to any
15 questions relevant to this lawsuit. I must accept
16 this advice or risk losing my 6th Amendment right
17 to effective representation. Accordingly, I assert
18 my federal constitutional rights as guaranteed by
19 the 5th, 6th and 14th Amendments of the United
20 States Constitution.
21 THE VIDEOGRAPHER: Mr. Kuvin, I'm sorry I have
22 to change.
23 MR. KUVIN: Go ahead.
24 THE VIDEOGRAPHER: We'll go off the record at
25 2:03. This will be the end of tape No. 2.
0191
1 MR. GOLDBERGER: Break time?
2 MR. KUVIN: No, not again. Please not.
3 Just let us know when you're good to go.
4 THE VIDEOGRAPHER: We're back on the record at
5 2:04. This will be the beginning of tape No. 3.
6 BY MR. KUVIN:
7 Q. Do you have security cameras throughout your
8 home on Palm Beach Island?
9 A. I'm going to answer that question the same way
10 I've answered most of your questions here today,
11 Mr. Kuvin. I intend to respond to all relevant
12 questions regarding this lawsuit; however, at the
13 present time, my attorneys have counseled me I cannot
14 provide answers to any questions relevant to the
15 lawsuit. I must accept their advice or risk losing my
16 6th Amendment right to effective representation.
17 Accordingly, I assert my federal constitutional rights
18 as guaranteed by the 5th, 6th and 14th Amendment to the
19 United States Constitution.
20 (Plaintiff's Exhibit No. 10 was marked for
21 identification.)
22 MR. KUVIN: I'll show the camera a photograph
23 here. Okay?
24 THE VIDEOGRAPHER: Lift it up. Yeah, there
25 you go. Okay.
0192
1 MR. KUVIN: Okay?
2 BY MR. KUVIN:
3 Q. Let me show you what we marked as Plaintiff's
4 Exhibit 10. Do you recognize this young lady?
5 A. Yes.
6 Q. Who is she?
7 A. Her name is Joanna Shogert (phonetic).
8 Q. And who is she?
9 A. I just -- her name is Joanna Shogert.
10 Q. How do you recognize her?
EFTA01158596
11 A. I don't understand the question.
12 Q. Well, is she a friend of yours? Did she work
13 for you? How do you recognize her?
14 A. How do I recognize her?
15 Well, I'd like to respond to that question
16 but, however, my attorneys have told me that I can't
17 respond to any questions today that may -- excuse me. I
18 intend to respond to all relevant questions regarding
19 this lawsuit; however, at the present time, my attorneys
20 have counseled me that I cannot provide answers to any
21 questions relevant to this lawsuit. I must accept their
22 advice or risk losing my 6th Amendment right to
23 effective representation. Accordingly, I assert my
24 federal constitutional rights as guaranteed by the 5th,
25 6th and 14th Amendment to the United States
0193
1 Constitution.
2 Q. Did you have sex with Joanna Shogert?
3 A. I'm going to answer that question like I've
4 answered most of your questions here today, which is, I
5 intend to respond to all relevant questions regarding
6 this lawsuit; however, at the present time, my attorneys
7 have counseled me I cannot provide answers to any
8 questions relevant to this lawsuit. I must accept their
9 advice or risk losing my 6th Amendment right to
10 effective representation. Accordingly, I assert my
11 federal constitutional rights as guaranteed by the 5th,
12 6th and 14th Amendment to the United States
13 Constitution.
14 Q. When did you first meet Prince Andrew?
15 And let me make it a compound question so I
16 don't have to repeat it over and over. When did you
17 first meet Prince Andrew, under what conditions did you
18 meet him, and who was present at that first meeting?
19 A. I'm going to answer that question as I've done
20 most of your questions here today, Mr. Kuvin, which is,
21 I intend to respond to all relevant questions regarding
22 this lawsuit; however, at the present time, my attorneys
23 have counseled me I cannot provide answers to any
24 questions relevant to that lawsuit. I must accept their
25 advice or risk losing my 6th Amendment right to
0194
1 effective representation. Accordingly, I must assert my
2 federal constitutional rights as guaranteed by the 5th,
3 6th and 14th Amendment to the United States
4 Constitution.
5 MR. PIKE: In addition, relevance.
6 BY MR. KUVIN:
7 Q. Do you pay Ms. Maxwell a salary?
8 MR. PIKE: Form.
9 BY MR. KUVIN:
10 Q. Ghislaine Maxwell, so we're clear. Do you pay
11 her a salary?
12 A. I'd like -- excuse me. I'm going to answer
13 that question the same way I've answered most of your
14 questions here today, which is, I intend to answer all
15 questions relevant to this lawsuit; however, at the
16 present time, my attorneys have counseled me I cannot
17 provide answers to any questions relevant to this
18 lawsuit. I must accept their advice or risk losing my
19 6th Amendment right to effective representation.
20 Accordingly, I assert my federal constitutional rights
21 as guaranteed by the 5th, 6th and 14th Amendment to the
EFTA01158597
22 United States Constitution.
23 Q. Did you provide any underaged girls for sex to
24 Prince Andrew?
25 MR. PIKE: Form.
0195
1 THE WITNESS: I'm going to respond to that
2 question the same way I've responded to most of
3 your questions here today, Mr. Kuvin, which is, I
4 intend to respond to all relevant questions
5 regarding this lawsuit -- excuse me, however, at
6 the present time, my attorneys have counseled me I
7 cannot provide answers to any questions relevant to
8 the lawsuit, or might be relevant to the lawsuit.
9 I must accept their advice or risk losing my 6th
10 Amendment right to effective representation.
11 Accordingly, I assert my federal constitutional
12 rights as guaranteed by the 5th, 6th and 14th
13 Amendment of the United States Constitution.
14 BY MR. KUVIN:
15 Q. Did you fly with Prince Andrew on your plane,
16 or planes, with any underaged girls, girls under the age
17 of 18?
18 A. I'm going to answer that question the same way
19 I've answered all the other questions here today,
20 virtually, which is, I intend to respond to all relevant
21 questions regarding this lawsuit; however, at the
22 present time, my attorneys have counseled me I cannot
23 provide answers to any questions relevant to the
24 lawsuit. I must accept their advice or risk losing my
25 6th Amendment right to effective representation.
0196
1 Accordingly, I must assert my federal constitutional
2 rights as guaranteed by the 5th, 6th and 14th Amendments
3 to the United States Constitution.
4 Q. Do you know Christine Drangsholt?
5 MR. KUVIN: For the court reporter, it's
6 D-R-A-N-G-S-H-O-L-T.
7 THE WITNESS: I intend to respond to all
8 relevant questions regarding this lawsuit; however,
9 at the present time, my attorneys have counseled me
10 I cannot provide answers to any questions relevant
11 to the lawsuit. I must accept this advice or risk
12 losing my 6th Amendment right to effective
13 representation. Accordingly, I assert my federal
14 constitutional rights as guaranteed by the 5th, 6th
15 and 14th Amendments to the United States
16 Constitution.
17 MR. KUVIN: Let me show the camera what we'll
18 mark as Exhibit 11.
19 (Plaintiff's Exhibit No. 11 was marked for
20 identification.)
21 THE VIDEOGRAPHER: Okay.
22 MR. KUVIN: Okay?
23 BY MR. KUVIN:
24 Q. In Exhibit 11, sir, you're standing with a
25 woman. Who is that woman in that photograph?
0197
1 A. Eula Maxwell (phonetic).
2 Q. Where were you?
3 A. I intend to respond to all relevant questions
4 regarding this lawsuit; however, at the present time, my
5 attorneys have counseled me I cannot provide answers to
6 any questions that may be relevant to this lawsuit. I
EFTA01158598
7 must accept this advice or risk losing my 6th Amendment
8 right to effective representation. Accordingly, I must
9 assert my federal constitutional rights as guaranteed by
10 the 5th, 6th and 14th Amendments to the United States
11 Constitution.
12 MR. KUVIN: And just so the court reporter
13 knows, Ghislaine is spelled G-H-I-S-L-A-I-N-E.
14 BY MR. KUVIN:
15 Q. Who is excuse
16 me?
17 A. I'm going to answer that question the same way
18 I've answered most of your questions here today, which
19 is, I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me I cannot provide answers to
22 any questions relevant to the lawsuit. I must accept
23 their advice or risk losing my 6th Amendment right to
24 effective representation. Excuse me. Accordingly, I
25 must assert my federal constitutional rights as
0198
1 guarantee -- guaranteed by the 5th, 6th and 14th
2 Amendment to the United States Constitution.
3 (Plaintiff's Exhibit No. 12 was marked for
4 identification.)
5 MR. KUVIN: Let me show to the camera what
6 we've marked as Exhibit 12.
7 BY MR. KUVIN:
8 Q. Let me show you what I've marked as Exhibit
9 12. Do you recognize any of the girls in that
10 photograph?
11 A. I'm going to answer that question the same way
12 I've answered most of your other questions here today,
13 Mr. Kuvin, which is, I intend to respond to all relevant
14 questions regarding this lawsuit; however, at the
15 present time, my attorneys have counseled me that I
16 cannot provide answers to any questions that may be
17 relevant to the lawsuit. I must accept their advice or
18 risk losing my 6th Amendment right to effective
19 representation. Accordingly, I assert my federal
20 constitutional rights as guaranteed by the 5th, 6th and
21 14th Amendment to the United States Constitution.
22 Q. Sir, isn't it true that in what we've marked
23 as Plaintiff's Exhibit 12, the blond standing on the
24 left is , and the blonde, dirty blonde
25 standing on the right is ?
0199
1 A. I intend to respond to all relevant questions
2 regarding this lawsuit; however, as I've done to most of
3 the questions at the present time, my attorneys have
4 counseled me that I cannot provide answers to any of
5 those questions that may be relevant to the lawsuit. I
6 must accept this advice or risk losing my 6th Amendment
7 right to effective representation. Accordingly, I
8 assert my federal constitutional rights as guaranteed by
9 the 5th, 6th and 14th Amendments of the United States
10 Constitution.
11 BY MR. KUVIN:
12 Q. I'm going to show you what we'll mark as
13 Exhibit 13. Let me show it to the camera, first.
14 (Plaintiff's Exhibit No. 13 was marked for
15 identification.)
16 BY MR. KUVIN:
17 Q. Sir, is it true that Exhibit 13 shows your
EFTA01158599
18 personal assistant,
19 A. I intend to respond to all relevant questions
20 regarding this lawsuit; however, at the present time, my
21 attorneys have counseled me that I cannot provide
22 answers to any questions that may be relevant to this
23 lawsuit. I must accept their advice or risk losing my
24 6th Amendment right to effective representation.
25 Accordingly, I assert my federal constitutional rights
0200
1 as guaranteed by the 5th, 6th and 14th Amendment to the
2 United States Constitution.
3 Q. Let me show you what we'll mark as Exhibit 14.
4 (Plaintiff's Exhibit No. 14 was marked for
5 identification.)
6 BY MR. KUVIN:
7 Q. Sir, does Exhibit 14 show , a
8 girl that you have had a sexual relationship with since
9 before she was 18 years old?
10 MR. PIKE: Form, argumentative, harassing,
11 assumes facts not in evidence, lacks appropriate
12 predicate and foundation.
13 THE WITNESS: I intend to respond to all
14 relevant questions regarding this lawsuit; however,
15 at the present time, my attorneys have counseled me
16 I cannot provide answers to any questions relevant
17 to this lawsuit. I must accept their advice or
18 risk losing my 6th Amendment right to effective
19 representation. Accordingly, I assert my federal
20 constitutional rights as guaranteed by the 5th, 6th
21 and 14th Amendment to the United States
22 Constitution.
23 BY MR. KUVIN:
24 Q. I'm going to show the camera what we'll mark
25 as Exhibit 15.
0201
1 (Plaintiff's Exhibit No. 15 was marked for
2 identification.)
3 BY MR. KUVIN:
4 Q. Sir, does Exhibit 15 show , an
5 underaged girl that you were utilizing back in 2005 and
6 2006 to procure other underaged girls for sex and sexual
7 contact at your home?
8 MR. PIKE: Same objections to Exhibit 15 as
9 were made to Exhibit 14.
10 THE WITNESS: I'm going to answer that the
11 same way I've answered most of your questions here
12 today, Mr. Kuvin, which is, I intend to respond to
13 all relevant questions regarding this lawsuit;
14 however, at the present time, my attorneys have
15 counseled me that I cannot provide answers to any
16 questions that may be relevant to the lawsuit. I
17 must accept their advice or risk losing my 6th
18 Amendment right to effective representation.
19 Accordingly, I am going to assert my federal
20 constitutional rights as guaranteed by the 5th, 6th
21 and 14th Amendments to the United States
22 Constitution.
23 (Plaintiff's Exhibit No. 16 was marked for
24 identification.)
25 MR. KUVIN: Let me show the camera what we've
0202
1 marked as Exhibit 16.
2 BY MR. KUVIN:
EFTA01158600
3 Q. Do you recognize the gentleman in that
4 photograph, sir?
5 MR. PIKE: Hold on for a second.
6 MR. GOLDBERGER: Do you want to discuss it
7 with me?
8 MR. PIKE: Let's take a break for one minute.
9 MR. KUVIN: All right.
10 THE VIDEOGRAPHER: Off the record at 2:16.
11 (A brief recess was taken.)
12 THE VIDEOGRAPHER: We're back on the record at
13 2:45.
14 BY MR. KUVIN:
15 Q. Okay. Do you recognize the person that's
16 shown in Exhibit 16?
17 A. Yes.
18 Q. Who is that?
19 A. Prince Andrew.
20 Q. And how do you know Prince Andrew?
21 A. I'm going to have to respond to that question
22 the same way I've responded to most of your questions
23 here today, Mr. Kuvin, which is, I intend to respond to
24 all relevant questions regarding this lawsuit; however,
25 at the present time, my attorneys have counseled me I
0203
1 cannot provide answers to any questions relevant to this
2 lawsuit. I must accept their advice or risk losing my
3 6th Amendment right to effective representation.
4 Accordingly, I assert my federal constitutional rights
5 as guaranteed by the 5th, 6th and 14th Amendment to the
6 United States Constitution.
7 Q. I'm going to show you a document that we'll
8 mark as Exhibit 17.
9 MR. PIKE: Thank you.
10 (Plaintiff's Exhibit No. 17 was marked for
11 identification.)
12 BY MR. KUVIN:
13 Q. I'm going to give you a minute to take a look
14 at that document and just tell me when you're ready to
15 answer any questions about it.
16 A. Okay.
17 Q. Okay. First of all, have you seen this letter
18 before?
19 MR. GOLDBERGER: Attorney-client privilege,
20 work product.
21 BY MR. KUVIN:
22 Q. Have you seen this letter before outside of
23 the relationship with your attorneys?
24 MR. GOLDBERGER: You can answer that question.
25 THE WITNESS: No.
0204
1 BY MR. KUVIN:
2 Q. Do you know Chief of Police Michael Reiter?
3 Do you know who he is?
4 A. I know who he is.
5 Q. Do you know State Attorney Barry Krischer?
6 A. I know who he is.
7 Q. Did you ever speak with Chief of Police
8 Michael Reiter in the past?
9 A. I don't remember.
10 Q. Did you ever talk to anyone, either at the
11 State Attorney's office, yourself, or Michael Reiter
12 about the prosecution of your claim without the presence
13 of your attorneys?
EFTA01158601
14 A. No.
15 Q. Did you ever talk to any of the police that
16 worked for the Town of Palm Beach without the presence
17 of your attorneys?
18 A. Explain --
19 MR. PIKE: Wait one second.
20 THE WITNESS: I'm sorry.
21 MR. PIKE: Can you state the question again?
22 MR. KUVIN: Sure.
23 BY MR. KUVIN:
24 Q. Did you ever speak to any of the police
25 officers that worked for the Town of Palm Beach without
0205
1 the presence of your attorneys?
2 MR. GOLDBERGER: Is the question, have you
3 ever spoken to a Town of Palm Beach police officer?
4 Is that the -- can we rephrase it like that?
5 MR. KUVIN: Sure.
6 MR. GOLDBERGER: Okay.
7 THE WITNESS: I've been stopped by the police
8 for traffic violations, if that's what you mean.
9 BY MR. KUVIN:
10 Q. Any other times that you had conversations
11 with any of the Town of Palm Beach --
12 A. No.
13 Q. -- police officers?
14 A. Not that I recall specifically.
15 Q. Okay. Now, you were housed at the jail after
16 your plea of guilty that we had spoke about at the
17 beginning of your deposition; is that correct?
18 MR. PIKE: Form.
19 THE WITNESS: Say it again.
20 BY MR. KUVIN:
21 Q. Yes. You were housed at the local jail here
22 in Palm Beach County after your plea of guilty that we
23 spoke about at the beginning of your deposition?
24 MR. PIKE: Form.
25 THE WITNESS: Yes.
0206
1 BY MR. KUVIN:
2 Q. How long were you there?
3 A. 13 months, approximately.
4 Q. All right. And of those 13 months, how many
5 months were you there where you had to stay there 24
6 hours a
7 A. I don't recall specifically.
8 Q. More than a month?
9 A. Yes.
10 Q. More than two months?
11 A. Yes.
12 Q. More than three months?
13 A. Yes.
14 Q. More than four?
15 A. I think so, I don't remember.
16 Q. Do you recall when you were provided work
17 release, when you were able to leave during the daylight
18 hours?
19 A. Not with specificity.
20 Q. While you were there at the jail in Palm
21 Beach -- I'm going to show you what we'll mark as
22 Exhibit 18.
23 (Plaintiff's Exhibit No. 18 was marked for
24 identification.)
EFTA01158602
25
0207
1 BY MR. KUVIN:
2 Q. Did you purchase items from the jail?
3 MR. GOLDBERGER: Hang on a second.
4 MR. PIKE: Hold on one second.
5 THE WITNESS: It looks that way, yes, sir.
6 BY MR. KUVIN:
7 Q. Okay.
8 MR. PIKE: And the document speaks for itself,
9 the composite document speaks for itself.
10 BY MR. KUVIN:
11 Q. I'd like you to take a look at Exhibit 18. It
12 shows purchases -- well, does it show purchases by you?
13 MR. PIKE: Asked and answered.
14 THE WITNESS: Yes.
15 BY MR. KUVIN:
16 Q. Okay. And it appears those purchases took
17 place from 7/8/08 through 9/30/08 is the last one that I
18 have; is that correct?
19 MR. PIKE: The document speaks for itself.
20 BY MR. KUVIN:
21 Q. You can answer.
22 A. The document speaks for itself.
23 Q. Is that correct, the last date is 9/30/08?
24 A. The last date here is 9/30, yes.
25 MR. PIKE: With regard to what you provided to
0208
1 the witness.
2 MR. KUVIN: Sure, absolutely.
3 THE WITNESS: Okay.
4 BY MR. KUVIN:
5 Q. And just so we're clear, this composite
6 exhibit that we've marked as Exhibit 18 contains
7 purchases from 7/8/08, 7/15, 7/22, 7/29, 8/5, 8/12,
8 8/21, 8/26, 9/2, 9/9, 9/23 and 9/30, just so the record
9 is clear; there is no question.
10 A. Okay.
11 Q. Okay?
12 A. Uh-huh.
13 Q. All right. These items that you purchased,
14 did you utilize all of these items yourself?
15 MR. PIKE: Form, relevance.
16 THE WITNESS: I don't understand the question.
17 BY MR. KUVIN:
18 Q. Well, you purchased a number of items that are
19 shown in this receipt.
20 A. Yes.
21 Q. The question is: Did you use them yourself?
22 MR. PIKE: Same objection.
23 THE WITNESS: I don't know if I used all of
24 them, so...
25
0209
1 BY MR. KUVIN:
2 Q. Well, what did you do with the items that you
3 purchased?
4 MR. PIKE: Form, overbroad.
5 BY MR. KUVIN:
6 Q. You can answer.
7 A. I used some, I threw away some.
8 Q. Did you give any away?
9 A. Not that I remember.
EFTA01158603
10 MR. PIKE: Same objection.
11 BY MR. KUVIN:
12 Q. Did you provide any items that you purchased
13 to other inmates while you were there in jail?
14 MR. PIKE: Form.
15 THE WITNESS: Not to the best of my
16 recollection.
17 BY MR. KUVIN:
18 Q. Okay. With respect to all of the items that
19 are listed in these receipts, is it a safe assumption
20 that you either used them yourself or threw them away?
21 MR. PIKE: Asked and answered. If you don't
22 know -- if you know.
23 THE WITNESS: I don't know.
24 BY MR. KUVIN:
25 Q. I'm sorry? I didn't hear you.
0210
1 MR. PIKE: Asked and answered.
2 THE WITNESS: So should I answer?
3 MR. PIKE: You can answer again.
4 THE WITNESS: Ask the question again.
5 BY MR. KUVIN:
6 Q. So can we assume that all of the items that
7 are shown in these receipts were either used by you or
8 thrown away?
9 A. I don't even know if I received some of those
10 items, so I would assume I used most of them.
11 Q. Okay.
12 A. Okay?
13 Q. Sure. Take a look, I just want to make sure,
14 did you receive all these items?
15 A. I don't know.
16 MR. PIKE: Asked and answered.
17 BY MR. KUVIN:
18 Q.
DataSet-9
Unknown
5 pages
LEOPOLD-KUVINL,
CONSUMER JUSTICE ATTORNEYS
May 6, 2010
CERTIFIED MAIL RETURN
RECEIPT REQUESTED
Re: Jeffrey Epstein
Dear
Enclosed please find a copy of Re-notice of Taking your Deposition which is now scheduled for
Tuesday, June 15, 2010 beginning at 10:00 a.m.
Please be advised that you are still under subpoena and your appearance at this deposition
is mandatory.
Should you have any questions, please don't hesitate to contact me at your convenience.
CRASHWORTHINESS • MANAGED CARE ABUSE CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH
EFTA00612092
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Case No: 10-80447-cv-Marmaohnson
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
PLAINTIFF'S RE-NOTICE OF TAKING VIDEO DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
DATE AND TIME: LOCATION:
June 15, 2010 Intelli
10:00 AM
upon an oral examination before Videographer and a Notary Public or officer authorized by law
to take depositions in the State of Florida. The oral examination will continue from day to day until
completed. The depositions are being taken for purposes of discovery, for use at trial or are being
taken for such other purposes as are permitted under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct co of this Notice was mailed this 7
to Jack A. Goldberger, .
Bruce E. Reinhart, Esq.,
obert D. Critton, Jr., Michael J. Pike,
LEOPOLD-KUVIN, P.A.
NEN.
Cc: Prose Court Reporting Florida Bar No: 089737
Visual Evidence
EFTA00612093
Farmer, Jaffe, Weissing,
air
Ian Action
Edwards, Fistos Et Lehrman,
Pe rsor.a: Injury
Wrotig10 Death
Commercial Litiganon
OJUSTICE.00M
May 7, 2010
Honorable Donald W. Hafele
Main Judicial Complex
Re:
it
Dear Judge Hafele:
. Jeffrey Epstein /Case No. 502008CA02t3051)OO(MB AB -and-
Jeffrey Epstein / Case No. 502008CP003626XXXXMB
.
Enclosed please find copies of Plaintiffs' proposed Agreed Orders concerning the hearing
on Defendant, Jeffrey Epstein's Motion for Partial Summary Judgment on Count I of Plaintiff's
Second Amended Complaint that took place on April 9, 2010, in the above-captioned matters.
Should both of these Agreed Orders meet with Your Honor's approval, please execute
same in both matters and provide conformed copies to all counsel in the enclosed prepaid self-
addressed envelopes provided.
If you have any questions, please feel free to call.
hank you for your time and attention to this matter.
End es as stated
GMF/nas
cc: Robert D. Critton, Esq. /
Jay Howell, Esq.
Jack Goldberger, Esq.
EFTA00612094
IN THE CIRCUIT COURT OF THE 15Th JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO: 502008CA028051XXXXMB AB
S
Plaintiff.
v.
JEFFREY EPSTEIN,
Defendant.
AGREED ORDER ON DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PARTIAL
SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT
THIS CAUSE came on to be heard on April 9, 2010 upon Defendant, Jeffrey Epstein's
Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint; the
Court having reviewed and considered the motion and the record and otherwise being fully
advised in the premises, it is hereby
ORDERED AND ADJUDGED that:
During the hearing, Plaintiffs counsel indicated a desire to amend the Complaint. As
such, the Court will deny as moot Defendant, Jeffrey Epstein's Motion for Partial Summary
Judgment on Count I of Plaintiffs Second Amended Complaint at this time so as to allow the
Plaintiff, • to file an Amended Complaint within twenty (20) days of the date of this Order.
Thereafter, Defendant. Jeffrey Epstein shall have twenty (20) days to file a responsive pleading.
DONE AND ORDERED at Palm Beach County Courthouse, Palm Beach County, Florida,
this day of 2010.
HONORABLE DONALD W. HAFELE
Circuit Court Judge
COoleS furnished to•
Gary M. Farmer, Jr., Esq.
Bradley J. Edwards. Esq.
Robert D. Critton, Jr., Esq.
Jay Howell, Esq.
Jack Alan Goldberger, Esq.
EFTA00612095
IN THE CIRCUIT COURT FOR THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM BEACH
COUNTY. FLORIDA
CASE NO. 502008CP003626XXXXMB
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
AGREED ORDER ON DEFENDANT. JEFFREY EPSTEIN'S MOTION FOR PARTIAL
SUMMARY JUDGMENT ON COUNT I OF PLAINTIFF'S SECOND AMENDED COMPLAINT
THIS CAUSE came on to be heard on April 9, 2010 upon Defendant, Jeffrey Epstein's
Motion for Partial Summary Judgment on Count I of Plaintiffs Second Amended Complaint; the
Court having reviewed and considered the motion and the record and otherwise being fully
advised in the premises, it is hereby
ORDERED AND ADJUDGED that:
During the hearing, Plaintiffs counsel indicated a desire to amend the Complaint. As
such, the Court will deny as moot Defendant, Jeffrey Epstein's Motion for Partial Summary
Judgment on Count I of Plaintiff's Second Amended Complaint at this time so as to allow the
Plaintiff, ■ to file an Amended Complaint within twenty (20) days of the date of this Order.
Thereafter, Defendant, Jeffrey Epstein shall have twenty (20) days to file a responsive pleading.
DONE AND ORDERED at Palm Beach County Courthouse, Palm Beach County, Florida,
this day of , 2010.
Copies furnished to: HONORABLE DONALD W. HAFELE
Gary M. Farmer, Jr., Esq. Circuit Court Judge
Bradley J. Edwards. Esq.
Robert D. Craton, Jr., Esq.
Jay Howell, Esq.
Jack Man Goldberger, Esq.
EFTA00612096
DataSet-9
Unknown
3 pages
From: Lesley Groff
To: "Erika A. Kellerhals PC"
Cc: Shauna Betz
Subject: Re: Jeffrey Epstein
Date: Wed, 25 Feb 2015 10:22:25 +0000
Good morning...I was just informed this deposition will not happen today...I am hoping you were
told! So sorry...apparently they are working on a reschedule. Thanks and take care, lesley
On Feb 4, 2015, at 1:29 PM, Erika Kellerhals wrote:
> Of course. We can also bring Jeffrey in via the back entrance so no one
> can photograph him coming in.
•
> Erika A. Kellerhals
> Member
> Kellerhals Fer•uson Kroblin PLLC
> email:
•
> Notice: This communication may contain privileged or other confidential
> information. If you are not the intended recipient, or believe that you
> have received this communication in error, please do not print, copy,
> re-transmit, disseminate, or otherwise use this information. Also, please
> indicate to the sender that you have received this e-mail in error, and
> delete the copy you received. Thank you.
> Circular 230: To ensure compliance with the requirements imposed by the
> IRS, we inform you that any tax advice contained in our communication
> (including any attachments) was not intended or written to be used, and
> cannot be used, for the purpose of (i) avoiding any tax penalty or (ii)
> promoting, marketing or recommending to another party any transaction or
> matter addressed herein.
> On 2/4/15 2:28 PM, "Lesley Groff" wrote:
>> Can we make sure someone is watching the door per Chet's request?
>>
>> On Feb 4, 2015, at 1:19 PM, Shauna Betz < > wrote:
>>
>>> February 25th the conference room is available all day, how much time
>>> would
>>> you like me to block off?
>>>
>>> Shauna Betz
>>> Legal Assistant
EFTA00352449
>>>
>>>
>>>
>>>
>>>
>>> emal :
>>>
>>>
>>>
>>> Notice: This communication may contain privileged or other confidential
>>> information. If you are not the intended recipient, or believe that you
>>> have received this communication in error, please do not print, copy,
>>> re-transmit, disseminate, or otherwise use this information. Also,
>>> please
>>> indicate to the sender that you have received this e-mail in error, and
>>> delete the copy you received. Thank you.
>>>
>>>
>>> Circular 230: To ensure compliance with the requirements imposed by the
>>> IRS,
>>> we inform you that any tax advice contained in our communication
>>> (including
>>> any attachments) was not intended or written to be used, and cannot be
>>> used,
>>> for the purpose of (i) avoiding any tax penalty or (ii) promoting,
>>> marketing
>>> or recommending to another party any transaction or matter addressed
>>> herein.
>>>
>>> Original Message
>>> From: Erika Kellerhals (mailto:
>>> Sent: Wednesday, February 04, 2015 2:14 PM
>>> To: Lesley Groff
>>> Cc: Shauna Betz
>>> Subject: Re: Jeffrey Epstein
>>>
>>> Shauna - please confirm that the conference room is available on this
>>> date
>>> for Mr. Epstein's deposition. Lesley - I'll give Chet a call today.
>>>
>>>
>>>
>>>
>>>
>>> Erika A. Kellerhals
>>> Member
>>>
>>>
>>>
>>>
>>>
>>> email:
>>>
>>>
>>>
>>> Notice: This communication may contain privileged or other confidential
>>> information. If you are not the intended recipient, or believe that you
>>> have received this communication in error, please do not print, copy,
>>> re-transmit, disseminate, or otherwise use this information. Also,
>>> please
>>> indicate to the sender that you have received this e-mail in error, and
>>> delete the copy you received. Thank you.
>>>
>>>
>>> Circular 230: To ensure compliance with the requirements imposed by the
EFTA00352450
>>> IRS, we inform you that any tax advice contained in our communication
>» (including any attachments) was not intended or written to be used, and
>>> cannot be used, for the purpose of (i) avoiding any tax penalty or (ii)
>>> promoting, marketing or recommending to another party any transaction or
>» matter addressed herein.
>>>
>>>
>>>
>>>
>>>
>>>
>» on 2/4/15 2:11 PM, "Lesley Groff" C wrote:
>>>
>>>> Hi Erika...Jeffrey needs to take a deposition for the Sitrick case he
»» is
>>>> involved in on Feb. 25th at 2pm STT time...I'm thinking you are
>>» probably
>>>> aware of this? Chet Brewer is representing him...Jeffrey and Chet want
>>» him to take the depo at your office. Chet says you do not need to be
>>» there, but he would like to make sure that someone is watching your
>>>> door
>>» (he is concerned about press) If you wanted to speak to Chet he is
>>>> happy
>>>> to talk with you.
>>>>
>>>> We wanted to make sure that Feb. 25th at 2pm would work on your end.
>>>> Please let me know.
>>>>
>>>> Chet Brewer:
>>>>
>>>> Thanks! Lesley
>>>
>>>
>>>
>>>
>>> This email has been checked for viruses by Avast antivirus software.
>>> http://www.avast.com
>>>
>>
EFTA00352451
DataSet-9
Unknown
156 pages
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA
FORT LAUDERDALE
Case No. 09-34791-RBR
Chapter 11
IN RE:
ROTHSTEIN ROSENFELDT ADLER, P.A.,
Debtor
VIDEOTAPED DEPOSITION
OF
JAMES N. HURLEY, ESQUIRE
Corporate Representative of Fowler White Burnett, PA
Friday, October 19th, 2018
10:05 a.m. - 2:29 p.m.
525 Okeechobee Boulevard, Suite 1200
West Palm Beach, FL 33401
Examination of the witness taken before
Sonja D. Hall
Palm Beach Reporting Service, Inc.
1665 Palm Beach Lakes Boulevard, Suite 1001
West Palm Beach, FL 33401
(561) 471-2995
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803632
L
1 APPEARANCES:
2 For Jeffrey Epstein:
3 LINK & ROCKENBACH, P.A.
1555 Palm Beach Lakes Boulevard, Suite 301
4 West Palm Beach, FL 33401
By SCOTT J. LINK, ESQUIRE
5 By JENNIFER LETTMAN, ESQUIRE
6
For Bradley Edwards:
7
SEARCY, DENNEY, SCAROLA, BARNHART &
8 SHIPLEY, P.A.
2139 Palm Beach Lakes Boulevard
9 West Palm Beach, FL 33409
By JACK SCAROLA, ESQUIRE
10
For Farmer Jaffe:
11
EDWARDS POTTINGER LLC
12 425 N Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
13 By Bradley Edwards, Esquire
14 For Fowler White:
15 CARLTON FIELDS, PA
525 Okeechobee Boulevard, Suite 1200
16 West Palm Beach, FL 33401
By JOSEPH IANNO, JR, ESQUIRE
17
18 ALSO PRESENT
19 Above & Beyond Reprographics
2161 Palm Beach Lakes Boulevard, Suite 412
20 West Palm Beach, FL 33409
By Manuel Santiago, Videographer
21
22
23
24
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803633
1 INDEX
2
3 Videotaped Deposition of JAMES N. HURLEY, ESQUIRE Page No.
4
5 Direct Examination by Mr. Scarola 6
6 Cross-Examination by Mr. Edwards 71
7 Cross-Examination by Mr. Link 105
8 Redirect Examination by Mr. Scarola 106
9 Recross-Examination by Mr. Link 126
10 Further Redirect Examination by Mr. Scarola 127
11 Recross-Examination by Mr. Edwards 150
12 Certificate of Oath 153
13 Certificate of Reporter 154
14 Read & Sign Letter to Witness 155
15
16 EXHIBIT INDEX
17
18 Letter Description Page No
19 A Re-Notice of Taking Video Deposition 7
20 B Exhibit Numbered Documents 44
21 C Produced Subpoena Duces Tecum Documents 109
22 D Various Bates-Stamped Documents 143
23 (Sealed and retained by Mr. Scarola)
24
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803634
4
1 THE VIDEOGRAPHER: We are on the video
2 record. This is the 19th day of
3 October 2018. The time is approximately
4 10:05 a.m.
5 This is the videotaped deposition of
6 the corporate representative of Fowler White
7 Burnett, P.A., In Re: Rothstein Rosenfeldt
8 Adler, PA.
9 This deposition is being held at 525
10 Okeechobee Boulevard, West Palm Beach, FL
11 33401.
12 My name is Manuel Santiago. I am the
13 videographer representing Above & Beyond
14 Reprographics.
15 Will the attorneys please announce
16 their appearances for the record?
17 MR. SCAROLA: My name is Jack Scarola.
18 I am counsel on behalf of Bradley Edwards.
19 MR. EDWARDS: Brad Edwards on behalf of
20 Farmer Jaffe.
21 MR. IANNO: Joseph Ianno, Carlton
22 Fields, on behalf of Fowler White.
23 MR. LINK: Scott Link and let Jennifer
24 Lettman on behalf of Mr. Epstein.
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803635
5
1 THEREUPON,
2 JAMES N. HURLEY, ESQUIRE,
3 being a witness in the notice heretofore
4 filed, and being first duly sworn in the above cause,
5 testified on his oath as follows:
6 THE WITNESS: I do.
7 MR. LINK: Mr. Scarola, before we begin
8 with questions, some housekeeping matters.
9 You have a subpoena -- the notice, at
10 least, with duces tecum.
11 MR. SCAROLA: Yes.
12 MR. LINK: So we have 182 pages of
13 documents to be produced. So I'm giving you
14 what we've marked as 1 through 182.
15 We have an additional set of documents
16 that are 183 through 215, that I do not
17 believe are responsive to your notice. They
18 are Bates-numbered emails. I don't know if
19 you want to have these produced and made
20 available to everyone or not.
21 MR. SCAROLA: Are those the documents
22 that have been identified on a privilege
23 log?
24 THE WITNESS: They very well may be.
25 They have Bates numbers on them. I do not
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803636
6
1 know if they were originally identified on a
2 privilege log, subsequently removed. I
3 don't know the status of them, but they may
4 very well have been originally on a
5 privilege log.
6 MR. SCAROLA: Let me see what you have.
7 We will talk about both of the groups of
8 documents you're producing today and we will
9 decide what, if anything --
10 MR. IANNO: One group I'm producing.
11 The second group I don't believe is
12 responsive, but I will produce it, if you
13 would like a copy of them.
14 MR. LINK: You have a copy for me of
15 the second group?
16 MR. IANNO: No, because I am not
17 producing them yet.
18 MR. LINK: You delivered them.
19 MR. IANNO: No, no. I didn't deliver
20 them. He's looking at them. I only have
21 one copy. My copy.
22 DIRECT EXAMINATION
23 BY MR. SCAROLA:
24 Q Would you please state your full name?
25 A John Norford Hurley.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803637
1 Q Mr. Hurley, how are you currently employed?
2 A I'm employed by Fowler White Burnett.
3 Q Are you appearing here today on behalf what
4 we will call Fowler White, for abbreviated purposes, in
5 response to a re-notice of taking video deposition of
6 the law firm?
7 A I am.
8 Q I am going to hand you a copy of that notice,
9 and ask you whether you have seen what has now been
10 marked as Exhibit A to this deposition previously.
11 A I have seen the notice of the deposition.
12 (Exhibit A was marked for identification.)
13 BY MR. SCAROLA:
14 Q Can you tell us, please, what role, if any,
15 you played in gathering documents that have been
16 produced in response to this notice of deposition duces
17 tecum?
18 A Together with our counsel, we reviewed
19 documents from our file to determine what was
20 responsive and what wasn't responsive.
21 Q I have been handed a package of documents,
22 which I have not yet had an opportunity to review. Can
23 you tell me, please, the procedure that was used to
24 gather those documents? Where did they come from?
25 A Those are documents which were maintained in
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803638
1 the Fowler White file. We have gathered them since
2 2017 to get all of our file materials together. We
3 have provided our file materials to our counsel.
4 I also reviewed emails from my Outlook box
5 subsequent to delivery of the files to counsel for
6 communications between myself and the Link &
7 Rockenbach firm as it pertain to review of our file
8 materials, and provided those. And they are part of
9 this as well.
10 Q I understand from that response that the
11 documents that we -- have produced today in response to
12 the subpoena -- were assembled into a file.
13 Could you tell us, please, where each of
14 the components of that file originated?
15 MR. IANNO: Object to the form.
16 THE WITNESS: I can't break it down by
17 document. I can tell you what we did in
18 order to gather the Epstein file materials
19 together.
20 BY MR. SCAROLA:
21 Q Thank you. Please do that.
22 A Sure. We did a -- IT did a search of all of
23 our systems, backups for anything pertaining to
24 Mr. Epstein. We looked at the various computers and
25 Outlooks for the attorneys involved in Epstein
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803639
9
1 communications to gather those emails from those, to
2 the extent that they weren't in our backup.
3 It turns out they all were in backup,
4 anyway, so a duplicate of what we found otherwise.
5 We had the hard materials in our file.
6 Again, this is a 2010 through 2012 basic time
7 period. For the most part, a lot of things were
8 being printed, and so we went through the hard
9 materials we had, as well, and then gathered
10 those -- not into a single file. They are
11 maintained in a single area, which is a protected
12 database that I have access to as general counsel of
13 the firm.
14 Q What were the search terms that were used in
15 reviewing electronically stored information?
16 A I don't know all the search terms we used.
17 We tried to be as comprehensive as we could to gather
18 anything that referred to Mr. Epstein. We used the
19 file numbers. I know that. I don't know of any other
20 terms we used beyond those.
21 Q We have learned through earlier
22 representations that have been made in connection with
23 this matter that a large number of boxes were produced
24 for review to the Link & Rockenbach firm, and that
25 subsequently those boxes were delivered to that firm.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803640
10
1 Did your search encompass any of the
2 contents of those boxes?
3 A Yes.
4 Q How?
5 A As far as the documents that were delivered
6 to the Link firm, they were done in two stages. The
7 first stage, the Link firm came to our office -- I
8 believe it was Scott and mostly Tina Campbell -- to
9 review the documents.
10 They flagged certain documents that they
11 wanted to have received. We provided copies of the
12 hard documents that they wanted copied. We provided
13 duplicate of a disc -- discs, plural -- that they
14 wanted duplicated. The hard copies of the documents
15 that were delivered to the Link firm at that time, a
16 copy of those were also put into my protected
17 directory.
18 The discs were not reproduced, so we did
19 not keep anything else from the disc. They were put
20 back in the original file.
21 The second production, when we gave up the
22 entire file of everything we had on this particular
23 matter, excluding our correspondence clips, which
24 were not produced, and which we have retained in our
25 office, we did not keep a copy of those.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803641
11
1 Q How many discs were contained within the
2 boxes that were produced for review by Link at the time
3 of that initial review?
4 A I have not added them up.
5 Q As you sit here today, do you know how many
6 discs were included within those boxes?
7 A Again, I have not added them up. I just know
8 it was multiple.
9 Q Did you personally see the number of discs?
10 A I'm not sure I understand that.
11 Q Was there a point in time when you looked at
12 the discs in the boxes so that, although you didn't
13 count them, you have some impression as to the number
14 of discs that were there?
15 A I did not view the disc within the boxes that
16 were delivered.
17 Q So as you sit here today, you have no way to
18 even estimate the number of discs that were produced to
19 Mr. Link?
20 MR. IANNO: Object to the form.
21 THE WITNESS: As I sit here today, I
22 cannot duplicate (sic) the number of discs
23 that were produced to Mr. Link. I believe
24 it can be done.
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803642
12
1 BY MR. SCAROLA:
2 Q How?
3 A When we sent the files to archives, there was
4 an index of the file materials by folder. And the
5 index itself references various discs included:
6 deposition discs, other types of discs that were in
7 there. And that would be the only way.
8 Q Do the documents that you produced today
9 include that index?
10 A No.
11 Q Is that index available?
12 A Yes.
13 Q Is there any reason why that index could not
14 be produced today? That is, do you have any reason to
15 believe that the index itself is in some way not
16 subject to production?
17 MR. IANNO: The answer is yes. To a
18 certain extent, it probably needs to be
19 redacted, depending upon what's on it,
20 because if it's anything like our file
21 index, there's probably privileged
22 information about subjects and things like
23 that.
24 MR. SCAROLA: So the answer today is, I
25 don't know.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803643
13
1 MR. IANNO: The answer is it could be
2 produced, but probably in a redacted, if not
3 entirely privileged form.
4 THE WITNESS: Further, in review of
5 that -- in review of the duces tecum, we
6 reached the conclusion jointly that it did
7 not fall within any of the areas
8 specifically defined by the duces tecum.
9 BY MR. SCAROLA:
10 Q As you sit here today, do you know how many
11 discs there were included within those 30-plus boxes
12 that contained electronically-stored information that
13 originated with the Rothstein Rosenfeldt Adler or
14 Farmer Jaffe law firms?
15 MR. IANNO: Object to the form.
16 THE WITNESS: As I sit here today, I
17 don't know if there were any discs in that
18 file that contains those materials.
19 BY MR. SCAROLA:
20 Q As you sit here today, do you know how many
21 discs there were within those files that had been
22 delivered to Fowler White in connection with procedures
23 followed responding to a subpoena that was issued to
24 the Rothstein Rosenfeldt Adler bankruptcy trustee?
25 MR. IANNO: Objection to form.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803644
1
1 THE WITNESS: We are talking about in
2 December of 2010?
3 BY MR. SCAROLA:
4 Q Yes, sir.
5 A It is my understanding, I believe, there were
6 two discs. I believe that's correct.
7 Q What were the contents of those discs?
8 A From my review of the file materials and
9 discussing the matters with the attorneys who were
10 involved in the case, approximately 27,000 or so pages
11 of documents that subsequently were dealt with in three
12 separate ways.
13 It's my understanding certain documents
14 were considered irrelevant, certain documents were
15 eventually deemed to be attorneys' eyes only, and
16 then documents contained within a privilege log.
17 Q Were the documents on the discs divided in
18 that manner?
19 MR. IANNO: Objection to the form.
20 Can you clarify which disc?
21 BY MR. SCAROLA:
22 Q The two discs that you are now referencing.
23 A I don't know how the documents I have
24 never seen those discs.
25 Q What is the basis of your statement that the
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803645
15
1 documents on the discs fell into the three categories
2 that you've described?
3 A In my review of various emails at the time,
4 subsequent emails going back and forth, discussions
5 with some of the attorneys involved in the matter.
6 Q You referenced approximately 27,000
7 documents. Is that the combined total of the pages on
8 both discs that you're referencing?
9 A I believe so, because there's an email from
10 Lilly Ann Sanchez, I believe, to Seth Lehrman in which
11 that figure was contained for a number of boxes that
12 were being sent to Seth Lehrman on December 10.
13 Q Do you know how many of the 27,000 documents
14 were contained on each of the two discs?
15 A I do not.
16 Q Did Fowler White receive both discs
17 simultaneously?
18 A I believe we received materials at one time.
19 Q When?
20 A They were picked up from Judge Carney's house
21 on December 7th of 2010 and Federal Expressed from our
22 Palm Beach office to our Miami office that day;
23 received in the Miami office on December 8th, 2010, I
24 believe.
25 Q How did you make that determine -- those
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803646
16
1 determinations?
2 A The review of emails in the file.
3 Q Were either of the two discs marked or
4 labeled in any way?
5 A I don't know how they were labeled, if at
6 all.
7 Q Do you know whether any discs delivered to
8 Mr. Link were labeled in any way?
9 A I don't know.
10 Q Describe for me, if you would, please, the
11 efforts that you undertook in order to be in a position
12 to speak on behalf of Fowler White during this
13 deposition.
14 MR. IANNO: Objection to form. On what
15 topics? There's none listed in the notice.
16 BY MR. SCAROLA:
17 Q Any topics.
18 A Again, I reviewed our file materials of a
19 period of time. I have talked to lawyers involved in
20 the case at the time. I have talked to their
21 assistants involved in the case at the time. I talked
22 to our IT personnel who were here at that time. I
23 talked to a file clerk who was here at that time.
24 Q Who are the lawyers within the Fowler White
25 firm at any time to whom you spoke?
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803647
17
1 A I talked to Lilly Ann Sanchez, Joe Ackerman
2 and Chris Knight.
3 Q Who are the IT personnel to whom you spoke?
4 A David Tobin.
5 Q Spell the last name for us, please.
6 A T-O-B-I-N.
7 Q Who was the law clerk to whom you spoke?
8 A Chris Hewitt.
9 Q Who among those individuals is still a Fowler
10 White employee?
11 A Everybody except for Ms. Sanchez.
12 Q Did you ever speak to Judge Carney with
13 respect to any matters relating to this disc or these
14 discs?
15 A I myself have not.
16 Q Did any agent of Fowler White at any time
17 within the last year speak to Judge Carney?
18 MR. IANNO: Object to form.
19 THE WITNESS: Our attorneys.
20 BY MR. SCAROLA:
21 Q Was any information conveyed by Judge Carney
22 relayed to you?
23 MR. IANNO: That just calls for a yes
24 or no answer, or I don't know.
25 THE WITNESS: Any information, yes.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803648
1 BY MR. SCAROLA:
2 Q What did Judge Carney relate to you regarding
3 the disc?
4 MR. IANNO: Judge Carney didn't relate
5 anything to him, so I am instructing him not
6 to answer. All of his information came from
7 his counsel.
8 BY MR. SCAROLA:
9 Q Have you taken into consideration any of the
10 information that you received from Judge Carney in
11 giving any of the responses that you have given thus
12 far?
13 MR. IANNO: Object to the form.
14 THE WITNESS: No.
15 BY MR. SCAROLA:
16 Q Have you personally had any conversation or
17 communication with Herb Stettin regarding the matters
18 that are the subject of the contempt proceedings that
19 are pending?
20 A No.
21 Q Have you had any conversation or
22 communication with Charles Lichtman regarding the
23 subject matter of the pending contempt proceedings?
24 A No.
25 Q Have you had any conversation or
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803649
19
1 communication with Robert Critton regarding the subject
2 matter of the contempt proceedings?
3 A No.
4 Q Have you any conversation or communication
5 with William Scherer regarding the subject matter of
6 the contempt proceedings?
7 A No.
8 Q Has any agent of Fowler White, to your
9 knowledge, had any communication with Herb Stettin,
10 Charles Lichtman, Robert Critton or William Scherer
11 concerning the subject matter of the contempt
12 proceedings?
13 MR. IANNO: Objection to form of the
14 question.
15 THE WITNESS: Not that I'm aware of.
16 BY MR. SCAROLA:
17 Q Upon receipt of the discs from Judge Carney
18 on December 7, what happened to them?
19 A They were Federal Expressed on the evening of
20 the 7th to our Miami office, for receipt on the 8th.
21 Q To whom were they directed in the Miami
22 office?
23 A I believe they were sent to Ms. Sanchez, but
24 I'm not positive.
25 Q What is Fowler White's understanding as to
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803650
20
1 why Judge Carney delivered discs to Fowler White on
2 December 7th?
3 A For us to apply Bates stamps to the documents
4 contained on that disc, to make a copy of the contents
5 of the disc for sitting -- returning to Farmer Jaffe.
6 Q And when you talk about a copy, are you
7 talking about a hard copy?
8 A A hard copy of the contents of the disc after
9 being Bates stamped.
10 Q Why were the discs delivered to the Miami
11 office?
12 A We had the facilities in the Miami office to
13 do this job.
14 Q What happened to the discs upon their
15 delivery to the Miami office?
16 A The documents from the discs were used for
17 making a set with Bates stamps applied using our firm's
18 software. Eventually the discs were returned to Judge
19 Carney.
20 Q Were the discs duplicated in whole or in part
21 prior to returning them to Judge Carney?
22 MR. IANNO: Object to the form of the
23 question.
24 THE WITNESS: No.
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803651
21
1 BY MR. SCAROLA:
2 Q When were the discs returned to Judge Carney?
3 A In December of 2010.
4 Q When in December of 2010?
5 A I believe, as best I can tell from the file,
6 approximately December 28th, 2010.
7 Q How many copies of the Bates-stamped contents
8 of the discs were made by Fowler White?
9 A I believe just one for sending to Farmer
10 Jaffe.
11 Q Was that copy sent to Farmer Jaffe?
12 A Yes.
13 Q How was it transmitted?
14 A By Federal Express.
15 Q When?
16 A December 10th, 2010.
17 Q Where were the discs maintained between
18 December 10, when the copying process was completed,
19 and December 28th, when they were delivered to Judge
20 Carney?
21 A I don't know.
22 Q Did Fowler White ever come into possession of
23 any other disc containing electronically-stored
24 information from either Rothstein Rosenfeldt & Adler or
25 Farmer Jaffe?
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803652
22
1 MR. IANNO: Object to form.
2 THE WITNESS: I don't know for sure. I
3 believe possibly at a later date.
4 BY MR. SCAROLA:
5 Q What is the source of that belief?
6 A It is my understanding -- I have been told --
7 I do not know this from personal knowledge -- that part
8 of the file delivered to Mr. Link's office contained a
9 disc that had materials in it. That disc was contained
10 in a file folder. And in my investigation into that
11 and discussions with people, it's my belief that we
12 received that file folder at a later date than when the
13 original copying took place.
14 Q What date?
15 A I don't know.
16 Q From whom?
17 A Again, I don't know.
18 Q What effort did you make to determine where
19 this disc delivered to Mr. Link came from?
20 A I interviewed the attorneys who were
21 involved. I talked to the file clerk. I talked to the
22 assistants that we still had with us, reviewed our file
23 materials to see if there was any reference in our file
24 materials. And that's pretty much the extent.
25 Q What leads you to believe that the disc that
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803653
23
1 was delivered to Mr. Link from your files originated as
2 a consequence of a disc having been delivered to Fowler
3 White at a later date than December 7, December 8 or
4 December 10?
5 MR. IANNO: Object to form. You can
6 answer if you understand.
7 THE WITNESS: Several aspects. First
8 of all, in my review of the emails at the
9 time of the original copying, Bates
10 stamping, indicate that the discs were being
11 returned to Judge Carney, as contained in an
12 email from Lilly Ann Sanchez to Mr. Lehrman,
13 I believe copied to a number of people.
14 Then we have this file folder. And,
15 again, I am going from what I have been told
16 by third parties, not related to our firm,
17 that the disc was in that file folder.
18 BY MR. SCAROLA:
19 Q Who told you that?
20 A Mr. Link's office.
21 Q Who?
22 A I don't recall.
23 Q Continue please.
24 A We took the file folder and we showed it to
25 the people I referenced earlier, if they recognized the
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803654
24
1 handwriting on the file folder. Nobody recognized the
2 writing on the file folder.
3 We showed the file folder to our clerk,
4 the file clerk pursued it, asked about the
5 handwriting. He said, I don't recognize the
6 handwriting. Furthermore, I don't recognize the
7 type of file folder. That's not something that we
8 traditionally used.
9 This is all from a photograph of the
10 folder that we received.
11 Q Is that photograph in these materials that
12 you produced?
13 A No.
14 Q Continue.
15 MR. IANNO: It kind of is. This is not
16 a photograph. It's a photocopy.
17 THE WITNESS: To be clear, that is not
18 the photograph that we were shown at the
19 time.
20 MR. IANNO: No. This is an actual copy
21 of the file folder. It's just not a
22 photograph of the folder.
23 THE WITNESS: The photograph of the
24 folder actually showed the folder in more
25 detail than what was produced to you
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803655
25
1 today -- or given to you today, I guess, is
2 a more proper term.
3 So between seeing the emails --
4 contemporaneous emails about the disc being
5 returned and my interviews with people, I
6 believe that we received that disc at some
7 later time.
8 I can't tell you when and from whom. I
9 have thoughts, but that's all they are.
10 BY MR. SCAROLA:
11 Q Share those thoughts with us, please.
12 MR. IANNO: No. They are just
13 speculation.
14 BY MR. SCAROLA:
15 Q That's all right. I want to hear them.
16 A Possibly from Judge Carney, when he was no
17 longer involved.
18 Q And as you say, that's nothing more than
19 speculation on your part.
20 A That's what I said at the beginning.
21 Q Have you been provided with any information
22 as to whether Judge Carney recognized the handwriting
23 on that disc?
24 A I have
25 Q The one delivered to Mr. Link.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803656
26
1 A I understand. I have not been.
2 MR. IANNO: The disc or the file
3 folder? I just want the record to be clear.
4 MR. SCAROLA: The disc.
5 BY MR. SCAROLA:
6 Q But you can also tell me about the file
7 folder. Has the handwriting on the file folder been
8 identified, to your knowledge?
9 A Not to my knowledge.
10 Q So if I understand your testimony correctly,
11 the only indication to you -- you meaning Fowler
12 White -- that this is not -- this meaning the disc
13 delivered to Mr. Link -- is not a duplicate copy of the
14 disc that was originally received by Fowler White on
15 December 7th, is the type of file folder in which it
16 was stored and the unidentified handwriting on the
17 disc. Is that correct?
18 MR. IANNO: Object to the form.
19 THE WITNESS: It's actually wrong on a
20 number of different levels.
21 BY MR. SCAROLA:
22 Q Okay. Tell me.
23 A I have no idea when that disc was burned that
24 we are talking about here.
25 MR. EDWARDS: When the disc was what?
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803657
2
1 THE WITNESS: Burned.
2 If it was Judge Carney's copy, it would
3 have been a duplicate disc at about that
4 time.
5 BY MR. SCAROLA:
6 Q At about what time?
7 A When the copies were being made, and sent the
8 hard copies to Farmer Jaffe and the Bates stamps being
9 applied.
10 What I'm saying is, I do not believe that
11 that disc was maintained in our file folder from
12 that time in December until sometime later on.
13 It is not just from the handwriting or the
14 type of folder. Again, it's my review of the
15 emails. It's my review of the file and the actions
16 of lawyers over the next two years fighting over the
17 privilege log and things along those lines.
18 Also, it's my review of how our lawyers
19 handled other documents in the file.
20 Q What is it about the way that Fowler White's
21 lawyers handled other documents in the files that
22 supports your speculation about the origin of the disc?
23 MR. LINK: Object to form.
24 THE WITNESS: There was extreme care
25 being taken to ensure that documents were
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803658
1 not seen by inappropriate people. I am
2 referring particularly to the attorneys'-
3 eyes-only documents.
4 There was a request from Roy Black to
5 view these documents. At the time, there
6 were email exchanges as to whether
7 Mr. Indyke would also be entitled to see
8 those.
9 And the idea was, no, he was not going
10 to be entitled to see those, that he would
11 not be shown those, even though he was a
12 lawyer, because everybody wanted to make
13 sure that it was restricted to Mr. Black and
14 not shown outside the scope of attorneys
15 that were involved in the Alan Gray's
16 (phonetics) legal affairs -- scope of the
17 various legal affairs.
18 BY MR. SCAROLA:
19 Q Attorneys'-eyes-only documents were shared
20 with Mr. Black?
21 A I don't know if they were eventually sent to
22 him. I don't recall that kind of email. I know that
23 there was an email about him looking at attorneys'-
24 eyes-only documents, and that led to the discussion
25 they would not be shown to Mr. Indyke because of his
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803659
29
1 relationship with Mr. Epstein. And everybody was in
2 agreement with that.
3 Q Who are the lawyers who reviewed attorneys'-
4 eyes-only documents that originated on the disc?
5 A I don't know.
6 Q Who are the Fowler White lawyers who viewed
7 attorneys'-eyes-only documents on the disc?
8 A I do not know.
9 Q What effort did you make to find out who had
10 viewed attorneys'-eyes-only documents on the disc?
11 MR. IANNO: Object to form.
12 THE WITNESS: They were not part of my
13 investigation.
14 BY MR. SCAROLA:
15 Q Did Fowler White determine why it was that
16 care was being taken to restrict access to information
17 that originated on the discs?
18 MR. IANNO: Object to the form of the
19 question. That's just a yes, no, or I don't
20 know answer.
21 I'm not sure we are going to get into
22 what Fowler White actually did, but you can
23 answer that question.
24 THE WITNESS: Can you state it again,
25 please? Or read it back.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803660
30
1 BY MR. SCAROLA:
2 Q Yes.
3 Did Fowler White determine why care was
4 being taken to restrict access to information that
5 had originated on those on that disc or those
6 discs?
7 MR. IANNO: Same objection.
8 THE WITNESS: Specifically as to why,
9 no.
10 BY MR. SCAROLA:
11 Q Did Fowler White become aware of the entry of
12 a court order that restricted access to information
13 contained on the discs.?
14 MR. IANNO: Object to the form of the
15 question.
16 THE WITNESS: I'm aware of an order
17 entered prior to delivery of the disc in
18 December. I'm aware of discussions
19 apparently regarding a confidentiality
20 order. I don't know if that was ever
21 entered subsequently.
22 BY MR. SCAROLA:
23 Q And what is it that Fowler White knows about
24 an order that was entered prior to delivery of the
25 discs on December 7?
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803661
1 MR. IANNO: Object to the form of the
2 question.
3 THE WITNESS: The order says that the
4 disc will be delivered to Fowler White, we
5 will apply the Bates stamp, send the copies
6 out, return the disc, and not retain any
7 copies within Fowler White's files.
8 BY MR. SCAROLA:
9 Q Does Fowler White agree that the retention of
10 a copy of that disc is in violation of that order?
11 MR. IANNO: Object to the form of the
12 question. Instruct you not to answer.
13 MR. SCAROLA: The basis of the
14 instruction?
15 MR. IANNO: Work-product privilege and
16 outside the scope of this deposition.
17 You're asking him to opine sitting here
18 as an expert witness on an, ultimately,
19 fact, apparently. But we are not here to
20 agree or disagree as to a court order.
21 You're here to get facts.
22 BY MR. SCAROLA:
23 Q Did Fowler White take steps to avoid
24 retention of any copy of the disc?
25 A Yes.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803662
32
1 Q What did it do?
2 A The method of Bates stamping required that
3 the disc be utilized by Mr. Tobin in our IT department.
4 Afterwards, any reference of those discs was deleted, I
5 believe, from the program and from his desktop
6 computer, temporary folder.
7 The copies were sent to Farmer Jaffe, as
8 required; and the disc returned to Judge Carney, as
9 required.
10 Q Who was Fowler White representing at the time
11 that it undertook the task of Bates stamping and
12 producing copies of documents contained on the disc?
13 A We were attorneys of record for Mr. Epstein.
14 Q Did Fowler White understand that it was in
15 possession of information that was privileged
16 information of an adversary?
17 MR. IANNO: Object to form, but you can
18 answer if you know the answer.
19 THE WITNESS: We understood that there
20 was a claim that certain documents were
21 privileged.
22 BY MR. SCAROLA:
23 Q During the period of time in question in
24 November of 2009 and December of 2009 -- excuse me
25 of 2010, did Fowler White's attorneys keep time records
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803663
1 with respect to any services that were being rendered
2 on behalf of Jeffrey Epstein?
3 A Yes, they did.
4 Q Are those time records still available?
5 A Yes.
6 Q Are those time records part of what has been
7 produced?
8 A No.
9 Q Why?
10 A They are privileged. Also, I'm not sure
11 they're entirely responsive.
12 Q Have you reviewed them in order to make a
13 determination as to whether there are responsive
14 entries in the time records?
15 A Not for that purpose, no.
16 Q Did any support personnel keep time records
17 with respect to services rendered on behalf of Jeffrey
18 Epstein during the period of time that Fowler White was
19 representing Jeffrey Epstein?
20 A Yes.
21 Q Who are the support personnel that kept time
22 records for Epstein-related services?
23 A There would have been various paralegals who
24 were working on the file.
25 Q Who are those individuals?
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803664
34
1 A I don't recall their names.
2 Q Did you interview any of those individuals?
3 A I did not. I did not see any involvement of
4 them with the disc or handling of the disc in my review
5 of the file materials.
6 Q Did you review their time records to see
7 whether or not the time records reflected any
8 involvement with the discs?
9 A I did.
10 Q Did they?
11 A Not that I saw.
12 Q Did Mr. Tobin keep time records with respect
13 to services that related to the representation of
14 Jeffrey Epstein?
15 A No.
16 Q Does Mr. Tobin keep time records with respect
17 to any of the services that he performed?
18 A No.
19 Q Did the equipment used to generate Bates-
20 stamped copies of documents from the disc record the
21 services performed in making those copies?
22 MR. IANNO: Object to form.
23 THE WITNESS: I'm not sure I understand
24 the question.
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803665
1 BY MR. SCAROLA:
2 Q Photocopy machines sometimes require that an
3 individual identification number be entered by keypad
4 on the machine, and that a case number be entered
5 before the machine will function to generate copies.
6 Was any such equipment that recorded user
7 or use employed with respect to these discs at any
8 time?
9 A That -- again, it's a two-part question. We
10 had the capability at that time to put in file numbers
11 if we were going to bill copies to files. Now it's
12 mandatory. At that time it wasn't mandatory. I have
13 reviewed what was available at the time.
14 Q What did you learn as a consequence of that
15 review?
16 A That there is no indication of copies being
17 made.
18 Q Did you make a determination as to why not?
19 MR. IANNO: Object to form.
20 THE WITNESS: Just a fact.
21 BY MR. SCAROLA:
22 Q Would it not have been part of the firm's
23 policies, practices and procedures to charge 27,000
24 copies to some specific file?
25 MR. IANNO: Object to form.
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803666
1 THE WITNESS: Our copy procedures are
2 more client-dependent than they are firm.
3 As you know, we have an insurance
4 practice. All of our insurance clients have
5 different policies regarding photocopies.
6 Exceptions are made in particular instances.
7 BY MR. SCAROLA:
8 Q Was Mr. Epstein charged for copies?
9 A No.
10 Q During the period of time that Fowler White
11 was representing Mr. Epstein, was Mr. Epstein ever
12 charged for copies?
13 A I believe so.
14 Q When was he charged for copies as opposed to
15 when he wasn't charged for copies?
16 MR. IANNO: Object to form.
17 MR. LINK: Mr. Hurley, one second. I
18 think you can answer that question, but we
19 are not waiving attorney-client privilege
20 between the Fowler White law firm and
21 Mr. Epstein, so I don't want any discussion
22 about strategic decisions, okay?
23 THE WITNESS: I understand.
24 It was a general rule that in the
25 normal day-to-day, Mr. Epstein was charged
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00803667
1 for copying.
2 BY MR. SCAROLA:
3 Q Why was there an exception to that rule in
4 connection with generating 27,000 plus copies in
5 connection with the task that you have described having
6 been performed in your Miami office sometime between
7 December 8th
DataSet-9
Unknown
15 pages
IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
L.M.,
CASE NO. 502008CA028051XXXXMB AB
Plaintiff,
v.
JEFFREY EPSTEIN
Defendant.
ORDER ON EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PROHIBIT
INAPPROPRIATE DEPOSITION QUESTIONS
THIS CAUSE came before the Court on Epstein's Motion for Protective Order to
Prohibit Inappropriate Deposition Questions, and the Court having heard argument of
counsel and being fully advised in these premises, it is hereby
ORDERED and ADJUDGED that: Defendant's Motion is hereb
Pi a °66PC, 1.1.2-4./tColAt WU_ A"--e-trts7
DONE AND ORDER at Palm Beach r ounty Courthouse, West Palm Beach,
Florida, this /T day of • 201
Copies furnished:
ROBERT D. CRITTON, JR., ESQ., and MICH EL J. PIKE, ESQ., 303 Banyan Boulevard, Suite 400,
West Palm Beach, FL 33401, BRADLEY J. EDWARDS, ESQ., Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, PL, 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK A.
GOLDBERGER, ESQ. Atterbury, Goldberger & Weiss, PA, 250 Australian Avenue South, Suite 1400,
West Palm Beach, FL 33401 and JAY HOWELL, ESQ., Jay Howell & Associates, P.A., 644 Cesery
Boulevard, Suite 250. Jacksonville, FL 32211
EFTA00723743
JONES
FOSI ER Flagler Center Tower, Suite 1100 Mailing Address
JOHNSTON 505 South Flagler Drive
West Palm Beach, Florida 33401
Post Office Box 3475
West Palm Beach, Florida 33402-3475
& STUBBS, P.A., Telephone (561)659-3000
Attorneys and Counselors
Joanne M. 'C 're
Direct Dial:
Direct Fax:
E-Mail:
January 15, 2010
Robert Critton, Esquire
303 Banyan Boulevard
Suite 400
West P FL 33401
Re: B.B. v. Jeffrey Epstein, Case No. 502008CA037319XXXXMB AB
Dear Bob:
In response to your correspondence dated January 5, 2010, enclosed please find
Responses and Objections to the subpoenas served on the Town of Palm Beach Police
Department Records Custodian and certain Town of Palm Beach police officers.
Pursuant to the line of case law originating with Gosman v. Luzinski, 937 So. 2d 293
(Fla. 41" DCA 2006), we are not under any present duty to provide you with a privilege
log identifying statutorily protected documents that we are not producing and will not
produce such a log at this time.
Finally, with regard to Administrative Order G.O. 11-65, we have produced two
documents to you. One document is the order effective January 15, 1999, as revised
on August 29, 2000 (note the language at the bottom of the first page of G.O. 11-65:
"'Revised 08/29/00"). I am advised by the Town Records Custodian that there is no
separate amendment dated August 29, 2000: The January 15, 1999 document was
simply revised and you have been provided the revised version. The second document
is the Order currently in effect as of June 15, 2009.
Sincerely,
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
By
oanne M. O'Connor
JMO:mtm
PftDOCSVI3156\003151.TR\1160772.DOC
www.fones-fostercom
IBIBIBWMVIMITEI
EFTA00723744
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 50 2008 CA 037319 XXXX MB AB
B.B.,
Plaintiff,
vs
JEFFREY EPSTEIN,
Defendant.
NON-PARTY TOWN OF PALM BEACH POLICE OFFICERS'
RESPONSE AND OBJECTION TO SUBPOENA DUCES TECUM
Non-parties, former Town of Palm Beach Chief of Police Michael Reiter, Captain
George Frick, Detective Joseph Recarey, Detective Michael Dawson and Detective
Michelle Pagan (collectively 'Town of Palm Beach Police Officers"), hereby file this,
their response and objection to the subpoenas duces tecum served on each of them as
follows:
GENERAL OBJECTIONS
As noted below, the Town of Palm Beach Police Officers have previously
produced documents responsive to this subpoena. In accordance with its obligations
under Section 119.07 of the Florida Public Records Law, the Town of Palm Beach
Police Officers have redacted a number of those documents in order to protect those
matters excepted from disclosure under Chapter 119, Fla. Stat. These areas of
redaction include, but are not limited to, the home addresses and telephone numbers of
the law enforcement personnel and any identifying information regarding the victims.
EFTA00723745
Such redaction is necessary because of the broad range of criminal intelligence and
investigative information regarding minor victims of sexual offenses under Florida
Statutes Chapter 794 and/or 800 sought by the subpoenas. The redactions made by
the Town of Palm Beach Police Officers may also include exempted personal
information including their home addresses, telephone numbers and social security
numbers.
RESPONSES AND OBJECTIONS TO DUCES TECUM
1. Any and all written reports, notes, memoranda or other papers authored
by you or any other member of the Palm Beach Police Department, whether in hard-
copy or electronic form, that relate to any law enforcement investigation of Jeffrey
Epstein including but not limited to the investigation that resulted in the filing of State
criminal charges against Mr. Epstein. This request includes any written communications
between you and any members of the Palm Beach Police Department, any member of
any Federal Law Enforcement Agency, any member of the United States Attorney's
Office, any member of the Office of the State Attorney, any representatives of the
media, any civil parties, any civilian witnesses and/or any lawyers or representatives of
any parents of any civilian witnesses.
RESPONSE: For all of the reasons set forth in response to Request No. 2
infra and incorporated herein, the Town Police Department objects to the request
to the extent that it seeks electronic communications. Aside from personal e-mall
of its employees, which the Town Police Department objects to producing for all
of the reasons set forth in Response to Request No. 2, infra, all documents
responsive to this request were produced on December 9, 2009.
2. Any and all electronic communications (EMAIL) between al any of the
following relating to any law enforcement investigation of Jeffrey Epstein including but
not limited to the investigation that resulted in the filing of State criminal charges against
him: (A) any member of the Palm Beach Police Department, (B) any member of any
Federal Law Enforcement Agency, (C) any member of the Untied States Attomey's
Office, (D) any member of the Office of the State Attorney (E) any member of any print,
television, or radio media outlet, (F) any attorney representing any civilian witness or
civil party who has filed or may potentially file a civil complaint against Mr. Epstein.
RESPONSE: The Town of Palm Beach Police Officers object to this request
on the grounds that it is unduly burdensome and seeks information that is
protected from disclosure under Florida's Public Records Law. The Town
reserves the right to submit a privilege log at the appropriate time should the
2
EFTA00723746
Court overrule its objections. See Gosman v. Luzinski, 937 So. 2d 293 (Fla. 4th
DCA 2006).
3. Any and all notes, memoranda or reports reflecting any communications
between you and counsel on behalf of Mr. Epstein, including but not limited to any
request for exculpatory evidence.
RESPONSE: None.
4. Any and all notes, memoranda or reports reflecting any attempts by you to
initiate or encourage a federal review of any facet/aspect of the Epstein investigation or
State prosecution of Epstein.
RESPONSE: Aside from the previously produced correspondence from
Michael S. Reiter to Barry E. Krischer dated May 1, 2006 and correspondences
from Michael S. Reiter to parents of victims dated July 24, 2006, no responsive
documents exist.
5. Any and all notes, memoranda or reports reflecting any complaints made
to the Palm Beach Police Department from any person, parent, or lawyer for any person
or parent claiming to have been a victim of any conduct of Mr. Epstein or from any other
private citizen of Palm Beach County relating to any conduct of Epstein from January 1,
2000-October 22, 2009.
RESPONSE: All responsive documents in the possession, custody or
control of the Town of Palm Beach Police Officers were produced on December 9,
2009.
6. Any and all notes, memoranda, or reports reflecting any communication
between You or and any other member of the Palm Beach Police Department with
"A.H."* in relation to her being subpoenaed to testify before or her requested attendance
before a State Grand Jury, including but not limited to any discussions regarding what
she would testify to and/or any preparation that any law enforcement officer provided
her with prior to any testimony.
RESPONSE: All responsive documents in the possession, custody or
control of the Town of Palm Beach Police Officers were produced on December 9,
2009.
7. Any and all notes, memoranda, or reports reflecting any communication
between you or any other member of the Palm Beach Police Department with "A.H."* or
referencing "A.H."* in relation to her being subpoenaed to testify before or her
requested attendance before a State Grand Jury where you or any Palm Beach police
officer or official sought to discourage her or influence her not to testify or to testify in a
certain manner at any Grand Jury proceeding involving Mr. Epstein.
3
EFTA00723747
RESPONSE: None.
8. Any and all agreements, memoranda, and/or notes of any kind, electronic
or otherwise, between you and any member of the Palm Beach Police Department, any
member of the Office of the State Attorney, and/or any member of the United States
Attorney's Office relating to any criminal charges, formal or otherwise, regarding "A.H."
at any time.
RESPONSE: None.
9. Any and all notes, memoranda, or reports of meetings or communications
between you and "S.G."*, her parents, or any lawyers who represent "S.G."
RESPONSE: All responsive documents in the possession, custody or
control of the Town of Palm Beach Police Officers were produced on December 9,
2009.
10. Any and all records of expenditures made or incurred by you, and all
requests for expenditures relating to the criminal investigation of Mr. Epstein.
RESPONSE: None.
11. Any and all logs, pictures, videos, digital information, reports, memoranda
or notes, and any record of expenditure, which relate to the institution of and/or
maintenance of any video surveillance of Mr. Epstein, his residence, or his visitors
during the following time periods:
a. January 1, 2004-December 31, 2004
b. January 1, 2005-December 31, 2005
c. January 1, 2006-December 31, 2006
d. January 1, 2007-December 31, 2007
e. January 1, 2008-December 31, 2008
f. January 1, 2009-today's date.
RESPONSE: None.
12. Any and all reports, logs, pictures, videos, notes, records of expenditures
or any other memoranda relating to any physical surveillance of Mr. Epstein, his
residence, his visitors, or any individual who was believed to be a potential witnesses or
co-conspirator other than the information relating to video surveillance that is requested
in request number 11.
RESPONSE: Photographs of Mr. Epstein taken by Detective Recarey will
be produced. The Town possesses no other responsive documents.
4
EFTA00723748
13. Any and all reports (including forensic reports), memoranda, notes, and
reports of any examination of any computer seized from Mr. Epstein's residence in
October 2005 or on any other occasion.
RESPONSE: None.
14. Any and all reports, memoranda, or notes reflecting a criminal theft or
burglary investigation of Mr. Epstein or his residence on any occasion prior to October
2005.
RESPONSE: All responsive documents in the possession, custody or
control of the Town of Palm Beach Police Officers were produced on December 9,
2009.
15. All cell phone records, both official cell phone and personal cell phone,
used by you between during the following time periods:
a. January 1, 2004-December 31, 2004
b. January 1, 2005-December 31, 2005
c. January 1, 2006-December 31, 2006
d. January 1, 2007-December 31, 2007
e. January 1, 2008-December 31, 2008
f. January 1, 2009-today's date.
RESPONSE: The Town of Palm Beach Police Officers object to this request
on the grounds that it seeks information that is irrelevant and not likely to lead to
the discovery of admissible evidence. The Town of Palm Beach Police Officers
further object on the grounds that the request is overly broad and unduly
burdensome. Finally, the Town of Palm Beach Police Officers object on the
grounds that the request seeks information that is specifically excepted from
disclosure under Florida's Public Records Law. See generally Non-Party Town of
Palm Beach Police Officers' Motion to Quash Subpoenas and/or Motion for
Protective Order, incorporated herein. The Town reserves the right to submit a
privilege log at the appropriate time should the Court overrule its objections. See
Gosman v. Luzinski, 937 So. 2d 293 (Fla. e DCA 2006).
16. All calendars or diaries, electronic or hard-copy, kept for the periods
between October 1, 2004 up through and including today, reflecting your schedules,
activities, meeting, etc.
RESPONSE: The Town of Palm Beach Police Officers object to this request
on the grounds that it seeks information that is irrelevant and not likely to lead to
the discovery of admissible evidence and as overly broad. The Town of Palm
Beach Police Officers further object on the grounds that the request seeks private
information that is not subject to disclosure as a public record under Section
5
EFTA00723749
119.011(1), Fla. Stat. and seeks statutorily protected information regarding the law
enforcement officers who made the calls and the persons to whom calls were
made including, but not limited, to family members, crime victims and
confidential informants. See generally Non-Party Town of Palm Beach Police
Officers' Motion to Quash Subpoenas and/or Motion for Protective Order,
incorporated herein. The Town reserves the right to submit a privilege log at the
appropriate time should the Court overrule its objections. See Gosman v.
Luzinski, 937 So. 2d 293 (Fla. 4th DCA 2006).
17. Any and all reports, memoranda, and notes of any communication
between y_qm and any member of the Office of the State Attorney relating to the criminal
investigation and subsequent prosecution of Mr. Epstein from October 1, 2004 up
through and including today.
RESPONSE: Aside from the previously produced correspondence from
Michael S. Reiter to Barry E. Krischer dated May 1, 2006, no responsive
documents exist.
18. All policies and procedures of the Palm Beach Police Department setting
forth the procedures for police officers, including the Chief, any detective and officers
when commenting to any media outlets, including but not liming to the local news, the
national media, print outlets, and any web-based media format.
RESPONSE: All responsive documents in the possession, custody or
control of the Town of Palm Beach Police Officers were produced on December 9,
2009.
19. All personal notes contained either on your personal computer, work
computer, and those that are handwritten containing any witnesses that y.clq, or any
other member of the Palm Beach Police Department interviewed or attempted to
interview with regard to the Epstein investigation from January 1, 2004, up through and
including today.
RESPONSE: None.
20. Any and all audio tapes of any witnesses that you or any member of the
Palm Beach Police Department obtained statements or interviews from, either sworn or
informal, with regard to the Epstein investigation.
RESPONSE: None.
21. Any and all audio tapes, notes (hand-written or typed), memoranda,
reports, messages, and/or any communications obtained or generated by you or any
member of the Palm Beach Police Department, either sworn or informal, that relate to
Jane Doe #4", who is the Plaintiff in a Federal Civil Case No. 08-80380 filed against
Jeffrey Epstein.
6
EFTA00723750
RESPONSE: The Town of Palm Beach Police Officers have no information
regarding the identity of "Jane Doe #4" and therefore cannot properly respond to
this Request Furthermore, the Town objects to producing any responsive
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject
to and notwithstanding its objections, the Town Police Department responds that
it possesses no responsive documents other than what has previously been
produced, unless those documents are encompassed within Request No. 2.
I HEREBY CERTIFY that a true copy of the foregoing instrument has been
furnished by United States mail to Theodore J. Leopold, Esquire and Spencer T.
Kuvin, Esquire, Leopold-Kuvin, P.A., 2925 PGA Boulevard, Suite 200, Palm Beach
Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger &
Weiss, P.A. 250 Australian Avenue South, Suite 1400, West Palm Beach, Florida
33401-5012; and Robert D. Critton, Jr., Esquire, Burman, Critton, Luther & Coleman,
LLP, 515 North Flagler Drive, Suite 400, West Palm Beach, Florida 33401, this
7.69-1-%-nayof January, 2010.
JONES, FOSTER, JOHNSTON & STUBBS,
P.A.
505 South Flagler Drive, Suite 1100
Post Office Box 3475
West Palm Beach, Florida 33402-3475
Telephone: 561-659-3000
Facsimile. 1-650-0465
PADOCS513156`40031SPLCA1753111.DOC
7
EFTA00723751
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CASE NO: 50 2008 CA 037319 XXXX MB AB
B.B.,
Plaintiff,
vs
JEFFREY EPSTEIN,
Defendant.
NON-PARTY TOWN OF PALM BEACH RECORDS CUSTODIAN'S
RESPONSE AND OBJECTION TO SUBPOENA DUCES TECUM
Non-party, Town of Palm Beach Police Department Records Custodian ("Town
Police Department"), hereby file this, her response and objection to the subpoenas
duces tecum served on her as follows:
GENERAL OBJECTIONS
As noted below, the Town Police Department has previously produced
documents responsive to this subpoena. In accordance with its obligations under
Section 119.07 of the Florida Public Records Law, the Town Police Department has
redacted a number of those documents in order to protect those matters excepted from
disclosure under Chapter 119, Fla. Stat. These areas of redaction include, but are not
limited to, the home addresses and telephone numbers of the law enforcement
personnel and any identifying information regarding the victims. Such redaction is
necessary because of the broad range of criminal intelligence and investigative
information regarding minor victims of sexual offenses under Florida Statutes Chapter
EFTA00723752
794 and/or 800 sought by the subpoenas. The redactions made by the Town Police
Department may also include exempted personal information regarding its law
employment officers and personnel including their home addresses, telephone numbers
and social security numbers.
RESPONSES AND OBJECTIONS TO DUCES TECUM
1. Any and all written reports, notes, memoranda or other papers authored
by any member of the Palm Beach Police Department and/or any of its employees,
members, agents, or representatives acting on behalf of the Palm Beach Police
Department whether in hard-copy or electronic form, that relate to any law enforcement
investigation of Jeffrey Epstein including but not limited to the investigation that resulted
in the filing of State criminal charges against Mr. Epstein. This request includes any
written communications between the Palm Beach Police Department and/or any of its
members, agents, or representatives acting on behalf of the Palm Beach Police
Department and any members of any Federal Law Enforcement Agency, any member
of the United States Attorney's Office, any member of the Office of the State Attorney,
any representatives of any media outlet, any civil parties, any civilian witnesses and/or
any lawyers or representatives of any parents of any civilian witnesses.
RESPONSE: For all of the reasons set forth in response to Request No. 2
infra and incorporated herein, the Town Police Department objects to the request
to the extent that it seeks electronic communications. Aside from personal e-mail
of its employees, which the Town Police Department objects to producing for all
of the reasons set forth in Response to Request No. 2, infra, all documents
responsive to this request on December 9, 2009.
2. Any and all electronic communications (EMAIL) between the Palm Beach
Police Department and/or any of its employees, members, agents, or representatives
acting on behalf of the Palm Beach Police Department and any of the following that
relate to any law enforcement investigation of Jeffrey Epstein including but not limited to
the investigation that resulted in the filing of State criminal charges against him: (A) any
other member of the Palm Beach Police Department, (B) any member of any Federal
Law Enforcement Agency, (C) any member of the Untied States Attorney's Office, (D)
any member of the Office of the State Attorney (E) any member of any print, television,
and/or radio media outlets (F) any attorney representing any civilian witness or civil
party who has filed or may potentially file a civil complaint against Mr. Epstein.
RESPONSE: The Town of Palm Beach Police Officers object to this request
on the grounds that it is unduly burdensome and seeks information that is
protected from disclosure under Florida's Public Records Law. The Town
reserves the right to submit a privilege log at the appropriate time should the
2
EFTA00723753
Court overrule its objections. See Gosman v. Luzinski, 937 So. 2d 293 (Fla. 4th
DCA 2006).
3. Any and all notes, memoranda or reports reflecting any communications
by the Palm Beach Police Department and/or any of its employees, members, agents,
or representatives acting on behalf of the Palm Beach Police Department with any
counsel on behalf of Epstein, including but not limited to any request for exculpatory
evidence.
RESPONSE: None.
4. Any and all notes, memoranda or reports reflecting any attempts by the
Palm Beach Police Department and/or any of its employees, members, agents, or
representatives acting on behalf of the Palm Beach Police Department to initiate or
encourage a federal review of any facet/aspect of the Epstein investigation or State
prosecution of same.
RESPONSE: Aside from the previously produced correspondence from
Michael S. Reiter to Barry E. Krischer dated May 1, 2006 and correspondences
from Michael S. Reiter to parents of victims dated July 24, 2006, no responsive
documents exist.
5. Any and all notes, memoranda or reports reflecting any complaints made
to the Palm Beach Police Department or any of its employees, members, agents, or
representatives acting on behalf of the Palm Beach Police Department from any person,
parent, or lawyer for any person or parent claiming to have been a victim of any conduct
of Mr. Epstein or from any other private citizen of Palm Beach County from 2000-2009.
RESPONSE: All responsive documents in the possession, custody or
control of the Town Police Department were produced on December 9, 2009.
6. Any and all notes, memoranda, or reports reflecting any communication
between the Palm Beach Police Departments and/or any of its employees, members,
agents or representatives acting on behalf of the Palm Beach Police Department with
"AA." in relation to her being subpoenaed to testify before or her requested attendance
before a State Grand Jury, including but not limited to any discussions regarding what
she would testify to and/or any preparation that any law enforcement officer provided
her with prior to any testimony.
RESPONSE: All responsive documents in the possession, custody or
control of the Town Police Department were produced on December 9, 2009.
7. Any State Grand Jury testimony that was sought or discouraged by the
Palm Beach Police Department or any of its employees, members, agents, or
representatives acting on behalf of the Palm Beach Police Department regarding any
contact with "A.H". relating to any investigation of Mr. Epstein.
3
EFTA00723754
RESPONSE: None.
8. Any and all agreements, memoranda, and/or notes of any kind, electronic
or otherwise, between the Palm Beach Police Department or any of its employees,
members, agents, or representatives acting on behalf of the Palm Beach Police
Department and any member of the Office of the State Attorney, and/or any member of
the United State s Attorney's Office relating to any criminal charges, formal or otherwise,
regarding "A.H"at any time.
RESPONSE: None.
9. Any and all notes, memoranda, or reports of meetings or communications
between the Palm Beach Police Department or any of its employees, members, agents,
or representatives acting on behalf of the Palm Beach Police Department and "S.G."*,
her parents, or any lawyers who represent "S.G"*.
RESPONSE: All responsive documents in the possession, custody or
control of the Town Police Department were produced on December 9, 2009.
10. Any and all records and requests of expenditures made or incurred by the
Palm Beach Police Department or any of its employees, members, agents, or
representatives acting on behalf of the Palm Beach Police Department relating to the
criminal investigation of Mr. Epstein.
RESPONSE: None. The Town Police Department does not generally
assign expenditures to specific cases.
11. Any and all logs, pictures, videos, digital information, reports, memoranda
or notes, and any record of expenditure, which relate to the institution of and
maintenance of any video surveillance of Mr. Epstein, his residence, or his visitors.
RESPONSE: None.
12. Any and all reports, logs, pictures, videos, notes, records of expenditures
or any other memoranda relating to any physical surveillance of Mr. Epstein, his
residence, his visitors, or any individual who was believed to be a potential witness or
co-conspirator other than the information relating to video surveillance identified in
request number 11.
RESPONSE: None.
13. Any and all reports (including forensic reports), memoranda, notes, and
reports of any examination of any computer seized from Mr. Epstein's residence in
October 2005 or on any other occasion.
4
EFTA00723755
RESPONSE: None.
14. Any and all reports, memoranda, or notes reflecting a criminal theft or
burglary investigation of Mr. Epstein or his residence on any occasion prior to October
2005.
RESPONSE: All responsive documents in the possession, custody or
control of the Town Police Department were produced on December 9, 2009
15. Any and all reports, memoranda, and notes of any communication by the
Palm Beach Police Department or any of its employees, members, agents, or
representatives acting on behalf of the Palm Beach Police Department and the Office of
the State Attorney relating to the criminal investigation and subsequent prosecution of
Mr. Epstein from October 1, 2004 up through and including today.
RESPONSE: All responsive documents in the possession, custody or
control of the Town Police Department were produced on December 9, 2009.
16. All policies and procedures regarding commentary to any media outlets,
including but not limited to the local news, the national media, print outlets, and any
web-based media format.
RESPONSE: All responsive documents in the possession, custody or
control of the Town Police Department were produced on December 9, 2009.
17. Any and all notes generated by the Palm Beach Police Department, its
employees, members, agents, or representatives acting on behalf of the Palm Beach
Police Department that concern or relate to any interviews or statements obtained
regarding the Epstein investigation from January 1, 2004, up through and including
today, including but not limited to notes that are handwritten, contained on any work
computer, and/or any personal computer.
RESPONSE: Aside from the Incident Report produced on December 9,
2009, no responsive documents exist
18. Any and all audio tapes of any witnesses that the Palm Beach Police
Department or any of its employees, members, agents, or representatives acting on
behalf of the Palm Beach Police Department obtained statements or interviews from,
either sworn or informal, with regard to the Epstein investigation.
RESPONSE: None.
19. Any and all personnel records of Michael Reiter, Detective Joseph
Recarey, Detective Michelle Pagan, and Detective Michael Dawson.
RESPONSE: None.
5
EFTA00723756
20. Any and all audio tapes, notes (hand-written or typed), memoranda,
reports, messages, and/or any communications, either sworn or informal, obtained or
generated by Palm Beach Police Department, its employees, members, agents, or
representatives acting on behalf of the Palm Beach Police Department that relate to
Jane Doe #4**, who is the Plaintiff in a Federal Civil Case No. 08-80380 filed against
Jeffrey Epstein.
RESPONSE: The Town of Palm Beach Police Officers have no information
regarding the identity of "Jane Doe #4" and therefore cannot properly respond to
this Request. Furthermore, the Town objects to producing any responsive
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject
to and notwithstanding its objections, the Town Police Department responds that
it possesses no responsive documents other than what has previously been
produced, unless those documents are encompassed within Request No. 2.
I HEREBY CERTIFY that a true copy of the foregoing instrument has been
furnished by United States mail to Theodore J. Leopold, Esquire and Spencer T.
Kuvin, Esquire, Leopold-Kuvin, PA, 2925 PGA Boulevard, Suite 200, Palm Beach
Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger &
Weiss, P.A. 250 Australian Avenue South, Suite 1400, West Palm Beach, Florida
33401-5012; and Robert D. Critton, Jr., Esquire, Burman, Critton, Luther & Coleman,
LLP, 515 North Flagler Drive, Suite 400, West Palm Beach, Florida 33401, this
of January, 2010.
JONES, FOSTER, JOHNSTON & STUBBS,
P.A.
505 South Flagler Drive, Suite 1100
Post Office Box 3475
West Palm 3402-3475
Telephone:
Facsimile:
By
bhn C. Randolph
PADOCSU31561.00315WW11753150.DOC
6
EFTA00723757