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16 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-CIV-MARRA/JOHNSON
JANE DOE #1 AND JANE DOE #2,
Plaintiffs,
vs.
UNITED STATES OF AMERICA,
Defendant.
REPLY IN SUPPORT OF MOTION
FOR LIMITED INTERVENTION BY ALAN M. DERSHOWITZ
Alan M. Dershowitz hereby replies in support of his Motion for Limited Intervention (DE
282).
Despite doubling and tripling down on her falsehoods about Alan M. Dershowitz (herein,
"Prof. Dershowitz"), Jane Doe #3 struggles to justify the vicious smears as having any relevance
to the issues in this proceeding. Her Response to Prof. Dershowitz's Motion for Limited
Intervention (DE 291) (herein "Response") offers no legitimate reason for defaming Prof.
Dershowitz in her Joinder Motion, and she has no right to continue to do so in this Court.
Strikingly, the Response does not explain why Jane Doe #3, discredited and disbelieved, and
with an obvious financial motive for fabrication of salacious accusations, waited almost seven
years to lob a bombshell into a proceeding in which she has no right to participate. The
Response does not account for why Jane Doe #3 never once asserted her accusations about Prof.
Dershowitz until a month ago even though the alleged transgressions supposedly occurred more
than twelve years ago. Although neither Jane Doe #3 nor anyone else had previously asserted
EFTA01136992
any wrongdoing by Prof. Dershowitz, now Jane Doe #3 cynically exploits the yoke of
victimhood to cheaply victimize others.
Jane Doe #3's Response is cheap indeed. At bottom, her Response is nothing but a
paper-thin pastiche of conspiracy theory and outright misrepresentation that crumbles upon the
slightest examination. Invocations of the Fifth Amendment by nonparty witnesses in response to
innocuous questions about Prof. Dershowitz are said to take on a "sinister cast"; yet these same
witnesses invoked their right against self-incrimination to almost every question asked of them,
including their parents' names. Prof. Dershowitz, as Epstein's former legal counsel, is one of
hundreds of people listed in an address book purloined by Jeffrey Epstein's butler; yet because
Prof. Dershowitz's name is circled in the address book by an unknown person for unknown
reasons, the argument is made that Prof. Dershowitz sexually abused a minor. The record shows
that while Prof. Dershowitz and Jane Doe #3 are both mentioned in the flight logs of Mr.
Epstein's private plane, they are never listed to have been on the same flight; Plaintiffs claim that
somehow that Prof. Dershowitz single-handedly orchestrated the destruction of logs without any
evidence of ability or possibility to do so. The increasingly hysterical accusations and insults are
both sad and ridiculous.
It is precisely this toxic mix of irrelevancy, malicious falsehood, and empty accusation
that justifies Prof. Dershowitz's intervention to, at least, strike the allegations against him. Jane
Doe #3 never had any need to drag Prof. Dershowitz into this action besides to wrongfully use
his good name and international stature to stir up media interest in her filing. This is
impertinence, plain and simple, and it has no place in this Court. Prof. Dershowitz therefore
urges the Court to either allow him to intervene to strike Jane Doe #3's allegations or deny Jane
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Doe #3's Joinder Motion so she is no longer afforded the ability to use the docket of this Court to
defame others.
I. Jane Doe #3's Continued Smears of Prof. Dershowitz
Demonstrate His Need to Intervene
Jane Doe #3 and her counsel's actions over the past month have confirmed that Prof.
Dershowitz's request for intervention stands upon dramatically different circumstances than
other intervention motions in this case, or any other case for that matter. Simply put, the scope
and tenor of their attacks against Prof. Dershowitz differ both in degree and in kind from other
reputational muggings conducted in the case before this Court. Nor is there a single reported
decision in federal case law in which the vitriol, severity, and length of the attacks against a
nonparty approach those levelled against Prof. Dershowitz here. What has become further
apparent is that if Prof. Dershowitz is not allowed to intervene, Jane Doe #3 and her counsel will
proceed with their attacks against him, all the more emboldened with complete impunity.
While Jane Doe #3 asks to "prove" her allegations against Prof. Dershowitz, she argues
paradoxically that he does not have "any direct interest" in defending these allegations. Instead,
she directs Prof. Dershowitz to defend the allegations that she makes in a contrived lawsuit filed
by her attorneys against him in Broward County Circuit Court for defamation. Moreover, the
law cited by Prof. Dershowitz, including the Sackman and Penthouse cases, demonstrates a need
and entitlement to intervene to vindicate his legitimate reputational interest that no other party is
situated to protect. "The individual's right to the protection of his own good name reflects no
more than our basic concept of essential dignity and worth of every human being — a concept at
the root of any decent system of ordered liberty..." Krause. v. Evolution Holdings, Inc., 975
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F.Supp. 2d 1247, 1260 (S.D. Fla. 2013); quoting Spencer v. Kenna, 523 U.S. I, 24 n. 5 (1998)
(Stevens, J., dissenting).
In an effort to cite contrary law to the Court, Jane Doe #3's Response takes remarkable
liberties in describing what is claimed to be the law to Court. For example, the Response quotes
Calloway v. Westinghouse Elec. Corp., 115 F.R.D. 73, 74 (M.D. Ga. 1987) for the proposition
that "a witness' interest in his reputation alone . . . does not constitute the required `interest
relating to the property or transaction which is the subject of the present action' necessary to
allow intervention as a matter of right." Yet what is excised from that quote through the ellipses
is the most crucial part of the case: "following a finding by a court that he is not credible."
Calloway actually stands for the proposition that a witness cannot intervene in a case as of right
if the Court has found him not credible in one of its orders. This finding has never been made as
to Prof. Dershowitz either in this Court, or in hundreds of others in which he has appeared.
II. Jane Doe #3's Lies About Prof. Dershowitz
Are Wholly Irrelevant to This Action
Meanwhile, Jane Doe #3 fails to come up with a single credible reason for naming Prof.
Dershowitz in her Joinder Motion. First, she claims she needed to drag Prof. Dershowitz's name
through the mud to prove that Jane Doe #3 was a victim of sexual abuse by Jeffrey Epstein. Yet,
in her Joinder Motion, she states that "[t]he Government was well aware of Jane Doe #3 when it
was negotiating the NPA, as it listed her as a victim in the attachment to the NPA." (DE 279 at
6.) If she was already listed as a victim on the NPA, why would they need to prove that further
by adding pages of scurrilous allegations against various individuals? And why did they have to
mention Prof. Dershowitz by name, when elsewhere they claim that "numerous prominent
American politicians, powerful business executives, foreign presidents, a well-known Prime
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Minister, and other world leaders" also committed sexual abuse, but keep those alleged figures
anonymous? The bad faith is apparent.
Second, Jane Doe #3 claims that she needed to name Prof. Dershowitz and others in the
Joinder Motion because of discovery disputes between the government and Jane Doe #1 and Jane
Doe #2. This does not even makes sense, legally or factually. Jane Doe #3's right to join in this
case has nothing to do with Jane Doe #1 and Jane Doe #2's entitlement to documents in
discovery. In fact, the discovery requests that Jane Doe #3 cites to in her Response as purported
cover for their sliming of Prof Dershowitz show that their argument is factually bogus. Prof.
Dershowitz is mentioned in only two of twenty-five requests for production propounded by Jane
Doe #1 and Jane Doe #2. (See Jane Doe #1 and Jane Doe #2's First Request for Production to
the Government Regarding Information Relevant to Their Pending Action Concern [sic] the
Crime Victims Act, at DE 225-1 at 26-38.) Both requests, nos. 8 and 21 seek his
communications with the government in his role as Mr. Epstein's defense attorney. There is no
issue of complicity or knowledge in any misconduct. Moreover, a fact conveniently omitted by
Jane Doe #3 is that Prof. Dershowitz is one of eleven lawyers whose communications Jane Doe
#1 and Jane Doe #2 sought in the requests for production. As the Court knows, Prof. Dershowitz
had no material connection to this case-as to the merits or as to discovery—before he was
dragged in by Jane Doe #3.
Third, Jane Doe #3 claims that the smears against Prof. Dershowitz are relevant to show
that Prof. Dershowitz had a motive to negotiate "confidentiality" and "blank check" provisions
into the NPA entered into between the government and Mr. Epstein. Again, this argument makes
no sense in the context of this case. Dershowitz's involvement in the agreement as one of
Epstein's attorneys, would have nothing to do with the negotiation of that agreement. The
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inclusion of certain provisions in the agreement simply has nothing to do with whether the
government complied with its obligations under the Crime Victims' Rights Act ("CVRA"). If
anything, it is the government's motive that would be at issue—although even that point is
doubtful—not the defense attorneys'. Moreover, because the first time Jane Doe #3 made these
contemptible allegations against Prof. Dershowitz was in her Motion for Joinder in December
2014, those allegations are irrelevant as to the inquiry of whether Jane Doe #3's rights under the
CVRA were violated at the time the NPA was entered. The government confirms that when Jane
Doe #3 was contacted by the FBI about this investigation, she clearly "stated that she did not
want to be involved in the federal investigation." (DE 290 at 6.) She was not "kept in the dark"
as she alleges in her Response. (DE 291 at 25.) Instead, she apparently chose to stay in the dark.
Moreover, she did not make any allegations against Prof. Dershowitz at the time the NPA was
entered, nor did she made any allegations against Prof. Dershowitz in her action for civil
damages in 2009, nor did she make any allegations against Prof. Dershowitz in her tape recorded
interview with her attorney in 2011. The first time these allegations surfaced were in connection
with Jane Doe #3's Motion for Joinder in this action. The allegations have absolutely no
relevance to the underlying issue of whether Jane Doe #3 was "treated with fairness" when the
NPA was entered, as the allegations against Prof. Dershowitz did not surface until approximately
eight years later.
Fourth, Jane Doe #3 then makes the facially absurd and libelous claim that somehow
Prof. Dershowitz benefited by the "co-conspirators" clause of the NPA. But the link between the
need to include these allegations and their ability to rescind the "co-conspirators" clause goes
completely unexplained. The allegations are completely gratuitous, as there is no such link. No
such claim existed until fabricated by Jane Doe #3 many years after the NPA was signed and
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fully performed. Additionally, as stated in Prof. Dershowitz's Supplement to his Motion for
Limited Intervention, this "co-conspirator" provision "was intended to apply to four alleged co-
conspirators, who were named in the original NPA and later redacted at their request.... Alan
Dershowitz was never alleged to be a potential co-conspirator." (DE 285 at 4.)
Incredibly, Jane Doe #3's counsel, Bradley Edwards, agreed with this reading of the NPA
in his Statement of Undisputed Fact during his own personal lawsuit against Jeffrey Epstein
(Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards, lawsuit (Case no. 502009-CA-
040800) in Palm Beach County Circuit Court. There, Edwards explained that these co-
conspirators were certain individuals who "procured minor females to be molested by Epstein."
(DE 291-15 at ¶ 27.) In fact, Edwards stated that "One of the co-conspirators —
— even participated in the sex acts with minors (including E.W.) and Epstein." (Id.)
Only now, when convenient as a way to try to justify allegations against Prof. Dershowitz does
Edwards argue that the "co-conspirator" provision was actually intended to protect Prof.
Dershowitz.
Fifth, Jane Doe #3 claims that she needed to include Prof. Dershowitz in her filing
because her CVRA claim of "unfair" treatment "implicates a fact-sensitive equitable defense
which must be considered in the factual context of the entire interface between Epstein, the
relevant prosecutorial authorities and the federal offense victims." The "facts" to which this
"defense" is sensitive, even if Jane Doe #3 is allowed to intervene, are the interactions between
the prosecutors and Jane Doe #3, and not anything pertinent to Prof. Dershowitz personally. Nor
are attorney-client communications between Epstein and his counsel at issue, or the proper
subject of discovery in this action under any scenario.
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III. Jane Doe #3's Efforts to Bolster Her Lies About
Prof. Dershowitz Are Remarkably Thin
Setting aside the utter irrelevancy of the allegations against Prof. Dershowitz, having
created an international imbroglio by their ill-conceived libels of Prof. Dershowitz, one would
expect that Jane Doe #3 would be able to muster at least some credible support for their
allegations. Yet the two "incontestable" facts she leads with in support of her claim that Prof.
Dershowitz is a serial sex abuser are (1) that Mr. Epstein and Prof. Dershowitz were friends; and
(2) Prof. Dershowitz visited Mr. Epstein's house. Of course, these supposedly "incontestable"
facts are evidence of nothing.
To further illuminate their patent ridiculousness, the Court needs only to read some of the
deposition testimony of Mr. Epstein's household employee that is attached to but not discussed
in the Response. Juan Alessi, the employee, testified that Mr. Epstein once hosted an elderly
Nobel Prize winning scientist or mathematician at his house. (DE 291-17 at 6.) On another
occasion he hosted a lunch at his house to honor Nobel Prize winners. (Id.) Under Jane Doe #3
and her counsel's logic, these men and women must not only be aware of alleged wrongdoing,
they must also be complicit.
Indeed, while the points raised above show a completely lack of investigation into the
scurrilous allegations, what is most remarkable about Jane Doe #3 Response is what it omits.
Approximately eight years ago, Jane Doe #3 participated in the authorities' investigation of Mr.
Epstein, and received a financial settlement from him. Yet she apparently never once mentioned
Prof. Dershowitz's now supposedly systematic sexual abuse of her to the prosecutors or to her
own lawyer. No explanation is given for this monumental inconsistency. Nor, despite his
supposed status as a co-conspirator in a scheme to cover up an underage sex abuse ring, is there
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any explanation given for the fact that Prof. Dershowitz was never even investigated—or even
mentioned—as a potential suspect. Meanwhile the present case has been proceeding for the last
seven years, but no explanation has been given for the timing of Jane Doe #3's effort to join this
case only last month.
IV. Prof. Dershowitz Immediately Responded to Jane Doe #3's Allegations
Against Him by Asking to Defend his Reputation
Jane Doe #3 also argues that Prof. Dershowitz should not be allowed to intervene because
"he has declined to defend his reputation in other actions." (DE 279, at 12.) It is without
question, however, that the Motion for Joinder filed by Jane Doe #3 on December 30, 2014 (DE
279), was the first time anyone has ever alleged that Prof. Dershowitz had any sexual contact
with a minor. It necessarily follows that this is the first opportunity Prof. Dershowitz has had to
defend his reputation related to "his involvement in Epstein's offenses." In fact, just six days
after these venomous and allegations were made, Prof. Dershowitz filed his Motion for Limited
Intervention. (DE 282.)
More specifically, Jane Doe #3 argues that when the civil lawsuit was brought by "one of
the underage females" against Epstein in 2009 (Doe v. Epstein, No. 9:08-80893-ICAM (S.D.
Fla.), "Dershowitz understood that counsel for many of Epstein's victims believed that mounting
evidence pointed toward his role extending beyond merely being an attorney for Epstein." (DE
279 at 13.) Despite this rank and self-serving speculation about what Prof. Dershowitz
"understood," there is not one piece of evidence which points to any allegations that he engaged
in any sexual contact with any minor, or even observed any criminal activity, prior to the
December 30, 2014 Motion for Joinder. Instead, the deposition testimony which Jane Doe #3
points to simply states that Prof. Dershowitz — who was Jeffrey Epstein's attorney — visited
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Epstein's home (Deposition Testimony of Alfredo Rodriguez at 199, 278, 279, DE 291-18,
herein, "Rodriguez Depo. Tr.") Rodriguez specifically testified that he has no idea whether
Prof Dershowitz had any contact at all with anyfemale.
Q. And did you have any knowledge of why [Dershowitz] was visiting there?
A. No ma'am.
Q. And do you have any idea whether or not Mr. Dershowitz was also receiving
massages?
A. I don't know, Ma'am.
Q. As to whether any of those women were ever associated with Mr. Dershowitz would it
be a correct statement that you have absolutely no knowledge?
A. I don't know, sir.
Q. Okay. Were you in any way attempting in your response to Ms. Ezell to imply that
Mr. Dershowitz had a massage by one of these young ladies?
A. I don't know, sir.
Q. You have no knowledge?
A. No, sir.
(Rodriguez Depo. Tr. at 279, 280, 385, 386.) To be sure, Rodriguez does testify that Prof.
Dershowtiz was at Epstein's home when underage females were present at the home — an
allegation which Dershowitz strenuously denies. However, Rodriguez did not testify that Prof
Dershowitz saw, interacted with, or touched any of these females. Instead, when asked what
Prof. Dershowitz did "while those girls were at the house," Rodriguez answered "He will read a
book with a glass of wine by the pool, stay inside." (Id. at 426, 427.) When asked if Prof.
Dershowitz ever even spoke to any of the girls, or "even knew that they were there" Rodriguez
answered "I don't know." (Id. at 427.)
Jane Doe #3 also relies upon the September 8, 2009 deposition testimony of Mr. Juan
Alessi to "corroborate" Jane Doe #3's sensational and false allegations regarding Prof.
Dershowitz. However, a more complete examination of that testimony reveals that Alessi did not
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make any allegations of any wrong doing by Dershowitz. (See, DE 291-17, hereinafter "Alessi
Depo. Tr.") Alessi testified that he saw "many celebrities" at the house, including certain
senators, Prince Andrew, Princess Sarah, Miss Yugoslavia, Miss Germany, "a lot of queens and
other famous people...[including] a very famous lawyer[] that I'm sure you know, Alan
Dershowitz, who spend [sic] at the house a couple times." (Alessi Depo. Tr. 70.) Alessi testified
that he also saw other celebrities including Robert Kennedy Junior, Frederick Fekkai, and even
various Noble Prize winners at the house. (Id. at 71.) However, Alessi made no allegations of
improprieties against any of these individuals. Jane Doe #3 asks the Court to infer that because
Prof. Dershowitz was at his client's home, he must have participated in nefarious activities. At
most, Alessi testified that Prof. Dershowitz visited Epstein's home and received a massage from
an adult massage therapist, which "was a treat for everybody" at the Epstein home. (Id. at 74)
("Q. Did [Dershowitz] have massages sometimes when he was there? A. Yes. A massage was
like a treat for everybody. If they want it, we call the massage and they have a massage.")
Alessi explains that he was referring to massages performed by adult massage therapists. (Id. at
184) ("Q. All right. And if I understood your testimony is, the ones the — that is, of the massage
therapists as you've just described [a hundred, 200 different massage therapists], you saw some
men? A. Yes. Q. You saw more women? A. Yes. Q. And all of the women, at least from your
viewpoint, were 18, 19 or older? A. Yes.")
Messrs. Alessi and Rodriguez did not allege that Prof. Dershowitz received a massage
from any underage females, had any physical contact whatsoever with any underage females, or
witnessed anyone engaging in any inappropriate behavior with any underage females.
Additionally, despite their allegations to the contrary, it is clear that previous testimony from
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Rodriguez and Alessi does not corroborate Jane Doe #3's baseless and utterly false affidavit.
(DE 291-1.)
Next, Jane Doe #3 claims that Prof. Dershowitz declined to defend his reputation in the
Edwards v. Epstein lawsuit (Case no. 502009-CA-040800) in Palm Beach County Circuit Court.
(Opp. to Mtn. to Intervene at 13.) In support of this allegation, Jane Doe #3 argues that her
attorney in the instant matter, Bradley Edwards contacted Prof. Dershowitz (through his attorney
Jack Scarola) to seek his voluntary cooperation in answering questions about Prof. Dershowitz's
client, Jeffrey Epstein's conduct. Prof. Dershowitz responded by letter stating
As you may know, I was Jeffrey Epstein's attorney when he submitted his guilty plea.
Accordingly, "any knowledge" I may have in connection with that plea is privileged
information. If you would let me know what non-privileged information you would seek
from me, I would then be able to decide whether to cooperate.
(DE 291-11.) Edwards' attorney responded by stating that based on "sworn testimony and
private interviews" he had "placed [Dershowitz] in the presence of Jeffrey Epstein on multiple
occasions... when Jeffrey Epstein was in the company of underage females subsequently
identified as victims." (DE 291 at 13, 14.) Again, no allegations were made at that time by
Edwards' attorney, or by anyone else, that Prof. Dershowitz engaged in any inappropriate
conduct or witnessed any inappropriate conduct related to Jeffrey Epstein and underage females.
Instead, Edwards was incorrectly seeking Prof. Dershowitz's cooperation for a civil suit between
Dershowitz's client, Jeffrey Epstein, and Edwards himself. Remarkably, because Prof.
Dershowitz did not agree to compromise his ethical obligations to his client, by voluntarily
cooperating with Epstein's adversaries, Jane Doe #3 argues that Prof. Dershowitz should not be
allowed to intervene in this action'.
Jane Doe #3's argument that he has not yet scheduled his deposition in this case, or the recently
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It is clear from the record, however, that Prof. Dershowitz acted immediately to defend
himself the first time any such allegations were made against him. In fact, just six days after
Jane Doe #3 filed her Motion for Joinder, which included vicious allegations against him, Prof.
Dershowitz filed his Motion for Limited Intervention. (DE 282.) Prof. Dershowitz should be
permitted to intervene for the limited purposes of moving to strike these outrageous and
impertinent allegations and to request a show cause order to the attorneys that have made them.
V. Jane Doe #3's Reliance on Other's Invocation of the
Fifth Amendment is Improper and Wholly Unpersuasive
Without a shred of physical evidence or witness corroboration for Jane Doe #3's
fantasies, she relies on invocations of the Fifth Amendment by Epstein as supportive of an
adverse inference as to Prof. Dershowitz. Given that Epstein was taking the Fifth Amendment
on all questions, and would have responded in the same way had the opposite questions been
asked, there is no inference against Prof. Dershowitz to be made from the invocation of the Fifth
Amendment by Epstein. Epstein's interest — in declining to answer any questions whatsoever —
was his own personal interest, not that of his lawyers, and lacks even minimal relevance.
Coquina Investments v. TD Bank, N.A., 760 F.3d 1300, 1310-11 (11th Cir. 2014)(adverse
inferences from the fifth amendment invocation by third parties allowed only where inference is
"trustworthy under all of the circumstances" including relationship, shared interest and control);
Kontos v. Kontos, 968 F.Supp. 400, 407-408 (1997)(no adverse inference allowed from
invocation of Fifth Amendment by sister of civil defendant in absence of "identity of interests");
Sebastian v. City of Chicago, 2008 WL 2875255 *3334 (N.D. Ill. 2008)(no adverse inference
filed defamation action, is of no moment. At the appropriate time, Prof. Dershowitz will of
course, appear for his deposition and testify that Jane Doe #3's allegations as to him are entirely
false. This, however, has no bearing as to whether the Court should permit the limited
intervention Prof. Dershowitz seeks.
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from invocation of Fifth Amendment in absence of close family or business relationship)2.
Similarly, any other witnesses taking the Fifth Amendment and remain silent to protect
themselves, are obviously, not creating any kind of evidence against Prof. Dershowitz.
Conclusion
In conclusion, if the Court grants Jane Does #3 and #4 motion for joinder (DE 279), then
Prof. Dershowitz's motion for limited intervention must be granted for such purposes as may be
appropriate including submitting a motion to strike and requesting an order to show cause, so as
to give him an opportunity to defend himself against harmful, spiteful and false allegations of the
worse kind. If the Court rejects the pending motion for joinder, then the Court should strike the
scurrilous allegations against Dershowitz, or, alternatively, determine the possible mootness of
his Motion for Limited Intervention.
Respectfully submitted,
Thomas Scott, Fla. Bar No. 149100
thomas.scottOcsklegal.com
COLE, SCOTT & KISSANE, P.A.
Dadeland Centre II
9150 South Dadeland Boulevard, Suite 1400
Miami, Florida 33156
Telephone:
2 The fact is that this controversy is not a swearing contest between two equally credible
witnesses. On one hand, Prof. Dershowitz is a world-renowned lawyer, professor, and author
with an impeccable personal and professional reputation. On the other, Jane Doe #3, who comes
into this case with no legitimate explanation for her delay in levelling these accusations against
Prof. Dershowitz, has obvious motives to seek financial gain. Her lack of credibility has
persisted over the years. When she previously made rape allegations against others, she was
deemed not credible by the State Attorney's Office in Palm Beach County., which declined to
bring a rape case as alleged by Jane Doe #3 "due to [her] lack of credibility and no substantial
likelihood of success at trial." Palm Beach Co. Sheriff's Office Offense Report, Case No.
98041883 at 19 (Feb. 28, 1998).
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Facsimile: (305) 373-2294
-and-
/s/ Kendall Coffey
Kendall Coffey, Fla. Bar No. 259681
[email protected]
Gabriel Groisman, Fla. Bar No. 25644
ggroisman®coffeyburlington.com
Benjamin H. Brodsky, Fla. Bar No. 73748
[email protected]
COFFEY BURLINGTON, P.L.
2601 South Bayshore Drive, PHI
Miami, Florida 33133
Telephone:
Facsimile:
Counselfor Prof. Alan M. Dershowitz
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by Notice of
Electronic Filing generated by CM/ECF, on this day of January, 2015, on all counsel or
parties of record on the Service List below.
/s/ Kendall Cotter
SERVICE LIST
Bradley J. Edwards Dexter Lee
FARMER, JAFFE, WEISSING, A. Marie Villafafia
EDWARDS, FISTOS & LEHRMAN, P.L. UNITED STATES ATTORNEY'S OFFICE
425 North Andrews Avenue, Suite 2 500 S. Australian Ave., Suite 400
Fort Lauderdale, Florida 33301 West Palm Beach, FL 33401
Telephone
Facsimile Fax:
E-mail: E-mail
E-mail
and
Attorneysfor the Government
Paul G. Cassell
Pro Hac Vice
S.J. Quinney College of Law at the
University of Utah
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone:
Facsimile:
E-Mail:
Attorneysfor Jane Doe #1, 2, 3, and 4
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DataSet-9
Unknown
7 pages
From: '
To: "brendan. [email protected]" , '
Cc: '
Subject: RE: David Rodgers Subpoena
Date: Wed, 05 Feb 2020 00:50:45 +0000
We'd like to go through a good chunk of the records on Friday, so it would probably be best to block off 3 hours just in
case. Would going until 1pm work for you, or would you rather start earlier?
Thanks,
Maurene
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: [email protected]
Sent: Tuesday, February 4, 2020 7:16 PM
To:
Cc:
Subject: Re: David Rodgers Subpoena
How long do you guys anticipate going on Friday? I had something unrelated come up in the early afternoon. If you think
we're going to go for more than a couple of hours, I'm happy to start earlier than 10.
Brendan F. Quigley
M +1.917.885.8069
On Feb 4, 2020, at 2:34 PM, wrote:
[EXTERNAL EMAIL)
Brendan,
In advance of Friday's meeting, wanted to give you a heads up that we expect to ask Mr. Rodgers about a discrete topic
that is related to our Epstein investigation just through the logs — it turns out that there is a missing person named
a teenager from Florida, who was last seen sometime around about August 1, 1997. In the flight logs,
there is an individual listed as "I (so, slightly different spelling) on an August 1, 1997 flight that's
designated as being from SAR to ZOR. The entry is the following:
EFTA00074322
On the one hand, given the spelling we thought perhaps it's a relative of your client; on the other, I don't see that name
listed on other dates around then, but that's just at a glance. In any event, we wanted to let you know we expect to ask
about it, and we're happy to discuss further with you in advance if that's useful.
thanks,
From:
Sent: Friday, January 31, 2020 15:20
To: [email protected]
Cc: andrew lanklerPbakerbotts.com;
Subject: RE: David Rodgers Subpoena
Sure, that works. Just let me know what time, and I'll meet you here.
Assistant United States Attorney
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
From: [email protected]
Sent: Friday, January 31, 2020 2:37 PM
To:
Cc: )
Cc: Lankier, Andrew .
Subject: RE: David Rodgers Subpoena
(EXTERNAL EMAIL]
EFTA00074323
Hi Brendan,
Mr. Rodgers's travel is booked, so we should be set for our meeting on 2/7. Can we please plan to start at 10am at 1St.
Andrews?
Also, we have received approval to make the materials you asked about available for your review in hard copy form at
our office in advance of the 2/7 interview. Please let me know when you would like to come down to complete that
review, and we'll get that set up for you.
Thanks,
Assistant United States Attorney
Southern District of New York
I St. Andrew's Plaza
New York NY 10007
=ISM
From: brendan.quigleyjbakerbotts.com
Sent: Thursday, January 30, 2020 11:07 AM
To:
Cc: [email protected];
Subject: RE: David Rodgers Subpoena
It's fine with me if Wendy or one of her colleagues calls him directly. I'll give him a heads up.
From:
Sent: Thursday, January 30, 2020 11:06 AM
To: Quigley, Brendan
Cc: • Lankier, Andrew .
Subject: RE: David Rodgers Subpoena
[EXTERNAL EMAIL)
Thanks very much, Brendan. I'll pass this all along to It is possible that or someone from her office will
need to reach out to Mr. Rodgers directly to arrange the travel logistics —is that alright with you, or would you rather I
ask them to contact you?
Assistant United States Attorney
Southern District of New York
I St. Andrew's Plaza
New York. NY 10007
EFTA00074324
From: [email protected]
Sent: Thursday, January 30, 2020 11:03 AM
To:
Cc: < >; [email protected];
Subject: RE: David Rodgers Subpoena
Thanks for talking before.
Here is Mr. Rodgers info for travel purposes
Lake Worth, FL 33467-7729
From:
Sent: Thursday, January 30, 2020 10:43 AM
To: Quigley, Brendan
Cc: < :rd• Lankler, Andrew .
Subject: Re: David Rodgers Subpoena
[EXTERNAL EMAIL]
Sure, I'm available until 11:30 at my desk— or the rest of the team should free up after 4pm today.
On Jan 30, 2020, at 10:31 AM, "[email protected]" wrote:
Sorry to circle back on this, but any chance one of you could talk this morning?
From:
Sent: Wednesday, January 29, 2020 6:44 PM
To: Quigley, Brendan
Cc: Lankler, Andrew . •
Subject: Re: David Rodgers Subpoena
[EXTERNAL EMAIL]
Hi Brendan— I'm free from 2pm onwards tomorrow, if that works for a call. We are available on 2/14, but let's discuss.
Sent from my iPhone
EFTA00074325
On Jan 29, 2020, at 5:21 PM, "[email protected]" wrote:
Would 2/14 work? If so, could we chat briefly on the phone tomorrow?
From:
Sent: Tuesday, January 28, 2020 10:15 AM
To: Quigley, Brendan
Cc: Lankler, Andrew .
Subject: RE: David Rodgers Subpoena
[EXTERNAL EMAIL)
Hi Brendan,
Thanks for the quick response. We're trying to be flexible, and to that end we could move this to the week of 2/10.
However, February 2151 would be a significant delay, especially given that we initially made this interview request in
July, and renewed those discussions in December. Let us know if you'd like to discuss further.
Thanks,
From: [email protected]
Sent: Monday, January 27, 2020 5:39 PM
To:
Cc: a [email protected]• >;
Subject: RE: David Rodgers Subpoena
We're still working through the issues I mentioned on the phone. We had hoped to have those resolved by now, but
they haven't been. Would it be possible to move the meeting to 2/21?
From:
Sent: Monday, January 27, 2020 12:39 PM
To: Quigley, Brendan
Cc: Lankler, Andrew ; •
Subject: RE: David Rodgers Subpoena
[EXTERNAL EMAIL)
Hi Brendan,
Our team has blocked off time to meet with your client on February 7th, along the lines we discussed. I wanted to
check in with you to see if the issues you had raised regarding the estate had been resolved. If so, please let us know
and we can move forward with travel arrangements.
Thanks,
EFTA00074326
From:
Sent: Tuesday, January 21, 2020 1:34 PM
To: brendan.quigleyBbakerbotts.com
Cc: [email protected];
Subject: RE: David Rodgers Subpoena
Hi Brendan,
Following up on our conversation from two weeks ago, I wanted to check to see if you have any updates on when we
might be able to schedule an interview with your client.
Thanks,
From:
Sent: Monday, January 6, 2020 3:10 PM
To: brendan.quigleyBbakerbotts.com
Cc: [email protected]•
›
Subject: RE: David Rodgers Subpoena
Hi Brendan,
Thanks very much. In terms of next steps, we would appreciate the opportunity to meet with your client for an
interview. I think we've discussed this before, but in general we continue to view your client as a witness, and we
would expect the interview would largely focus on the flight records you've produced. We don't anticipate that we
would need to speak with your client for much longer than an hour or so, in case that helps give a sense of what we
have in mind. I think you mentioned that your client is based in Florida, so we're happy to discuss arranging logistics
to work out something convenient for you and your client.
Please let us know if a call would be useful to discuss further, and thanks again for sending records earlier today.
Best,
From: brendan.quigleyBbakerbotts.com
Sent: Monday, January 6, 2020 10:13 AM
To:
Cc: [email protected]
Subject: RE: David Rodgers Subpoena
We hope you had a good holiday season.
We attach additional flight logs for David Rodgers, reflecting flights between 1991 and January 2006. Again, we ask
that these records be kept confidential.
EFTA00074327
Best regards,
Brendan
From: Quigley, Brendan
Sent: Friday, December 20, 2019 10:55 AM
To: <
)
Cc: Lankler, Andrew
Subject: David Rodgers Subpoena
We attach flight logs for David Rodgers, dated between January 23, 2006 and September 19, 2013. We understand
that these records will be kept confidential, pursuant to Fed. R. Crim. P. 6(e).
As discussed on the phone last week, we are in the process of obtaining and reviewing additional materials and
anticipate making further productions to you on a rolling basis.
Best regards,
Brendan F. Quigley
Brendan F. Quigley
Partner
Baker Botts L.L.P.
brendan.quigley@bakerbot .com
T +1.212.408.2520
F +1.212.259.2520
M +1.917.885.8069
30 Rockefeller Plaza
New York, NY 10112
Confidentiality Notice:
The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be
privileged and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than
the recipient[s] listed above is prohibited. If you have received this message in error, please notify the sender immediately at the
email address above and destroy any and all copies of this message.
EFTA00074328
DataSet-9
Unknown
2 pages
From: (BA) (FBI)"
To: (NY) (FBI)" alMM>
Subject: Re: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Date: Mon, 24 Feb 2025 20:09:26 +0000
Importance: Normal
Inline-Images: image001.png
Hey no worries.
Wee did not seize documents during Maxwell's arrest. As far as footage from Palm Beach, the only video was
Palm Beach PDs video walkthrough of their search warrant from 2005.
Special Agent -
FBI Baltimore/Delaware
Violent Crime Safe Streets Task Force
From: . (NY) (FBI)
Sent: Monday, February 24, 2025 2:50:41PM
To: (BA) (FBI).c >
Subject: Fw: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Sony, I see you are out of office. Are you able to provide clarification on #2 below regarding additional docs, or
#3 video footage from Palm Beach residence?
From: (CID) (FBI) MIIIMIME>
Sent: Monday, February 24, 2025 2:07:52 PM
To: a NY) (FBI)
Cc: (CID) (FBI)
Subject: Fw: OCA REQUEST: Letter from Senator Blackburn to Director Patel
I just got this and will be pulling together a response with talking points on what we've previously submitted (as
I usually do with these requests) and the most recent files you sent along.
The only one I am not 100% on is probably going to be #2 and whether there are any other documents outside of
the address book.
To my knowl dfe, there is no video surveillance from the Palm Beach residence.
I am in Houston for the CAC Basic training today but will be back in Linthicum tomorrow / Wed.
-
Respectfully,
Unit Chief
EFTA00154690
Crimes Against Children & Human Trafficking Unit
Criminal Investigative Division
Desk:
Mobile:
From:
Sent: Monday, February 24, 2025 12:49:53 PM
To:
Cc: . (CID) (FBI)
(CID) (FBI) (CID) (FBI)
(CID) (FBI) (CID) (CON)
Subject: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Good afternoon,
On February 24, Senator Blackburn wrote to Director Patel regarding the Jeffrey Epstein investigation and
evidence. In her letter, she requests the following:
1. The complete flight logs from Jeffrey Epstein's private jet and helicopter.
2. Any records that were in Ghislaine Maxwell's possession that contain the names of individuals associated
with Ms. Maxwell or Mr. Epstein, including but not limited to Maxwell's "little black book."
3. All video surveillance footage from Jeffrey Epstein's Palm Beach, Florida, residence.
4. Any other documents, records, or memoranda related to the Jeffrey Epstein and Ghislaine Maxwell
matters.
If there are any materials that Senator Blackburn has requested in her letter, which we are able to provide,
please include when submitting responses. If not, please address why the materials/information cannot be
shared.
Talking points repository has an Epstein summary which may be useful to reference. It is available here: El
Epstein.
Please send responses back by COB Tuesday, March 4 with SC approval.
Best,
Management and Program Analyst
Criminal Investigative Division
Executive Staff Unit (ESU)
Desk: ext
EFTA00154691
DataSet-10
Unknown
2 pages
From: 1 <->
Sent: Sunday, March 13, 2011 12:51 AM
To: Jeffrey Epstein
Lawyers drag prince into underage sex scandal
The deposition of a model =ho worked for Jeffrey Epstein raises questions about the prince's =udgement
Michael Bilton, Kate Mansey and John Harlow
Published: 13 March =011
• Recommend (0)
• Comment (0)
Print
Follow News
Jeffrey Epstein =ired Adrianna to work at his mansion (Neil =asmuss)
A former top model who worked for a paedophile friend of =rince Andrew has been questioned under oath about
whether the royal was =nvolved with underage girls.
Legal documents obtained by The Sunday Times show that =driana was asked if the Duke of York was linked to the
scandal =urrounding his billionaire friend Jeffrey Epstein.. is one of four =omen who worked for the US financier
who were named as "potential =o-conspirators" when Epstein was convicted of sex offences involving = minor. In a
videotaped interview during subsequent civil proceedings, =awyers asked "Has Prince Andrew ever been involved
with =nderage minor females to your knowledge?"
Invoking the US constitution's =ifth amendment, which protects against self-incrimination, Polish-born =oss, 27, replied:
"I refuse to answer." She was also asked "Have =ou ever met Prince Andrew?" and "Have you ever flown on
(Epstein'sJ=plane with Prince Andrew?" refused to answer.
Flight logs show that Andrew was a =assenger on Epstein's jet in May 2000. In interview it was =lleged that the
former Elite agency model travelled on the aircraft =ore than 50 times. It has been claimed that Epstein abused young
girls =n the jet.
There is no suggestion that Andrew had sexual contact with =ny of the girls or that he knew Epstein abused them.
deposition will raise =ore questions about the prince's judgment after he met the =illionaire in New York in
December following Epstein's release from =rison.
Allegations have been made against Epstein by up to 40 girls, =ith at least 17 cases settled out of court. Epstein is said to
have =bused girls as young as 12. He secured protection for his associates =hrough a non-prosecution agreement. The
federal document names as = possible co-conspirator.
EFTA_R1_00096269
EFTA01779205
Lawyers acting for Epstein's victims in the civil courts =re challenging the agreement and claim it may lead to Andrew
being =sked to give evidence.
In an interview with Bradley Edwards, a lawyer who represents =ome of the victims,. said she moved to Florida in
2002 after Elite =btained a visa for her to work in America. The model was then hired to =ork in Epstein's Palm Beach
mansion and organised his diary. She was =1his side in 2005 at a New York launch party for one of Epstein's =agazines.
name was found on messages and notes seized by =etectives from the Florida property.
During the interview, she refused to answer any questions =bout her involvement with Epstein.
The other "potential co-conspirators", who are thought to =ave helped to procure girls for Epstein, are named as
=adia and Lesley Groff.
Epstein, 58, served 13 months in prison for soliciting a =inor for prostitution and soliciting prostitution. He will remain on
=he sex offenders' register for life.
His friend Ghislaine Maxwell, 49, the daughter of Robert =axwell, the late media tycoon, was one of Epstein's closest
aides and =s alleged in legal papers to have hired underage girls for him, joining =n the sex games, which she denies.
, one victim, told =ow she was kept as Epstein's paid sex slave for four years from the =ge of 15.
She said Epstein introduced her to Andrew, who she says she =et three times.
It emerged last week that Epstein paid £15,000 to settle a =ebt for the Duchess of York. Royal sources said Andrew was
"unwise" =o have remained in contact with Epstein but state he has now severed =ies.
Neither nor her lawyer responded to questions put by The =unday Times.
2
EFTA_R1_00096270
EFTA01779206
DataSet-9
Unknown
3 pages
From: (NY) (FBI)" alMIE>
To: (NY) (FBI)"
Cc: (NY) (FBI)"
Sent: Tuesday, May 6, 2025 11:29:30 AM
To: (NT) (FBI) 'c lb
Cc: • (NT) (FBI) ‹ >
Subject: Re: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Did we ever get the response?
ASAC
FBI NY Violent Crime Threat
Cell:
From: . (NY) (FBI) < >
Sent: Tuesday, May 6, 2025 11:09:58 AM
To: (NY) (FBI) < >
Cc: • (NY) (FBI)
Subject: Fw: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Attached is the letter from Senator Blackburn and tasking. This was responded to in parts.
From: (NY) (FBI) < >
Sent: Tuesday, February 25, 2025 12:57 PM
To: MIE • (NT) (FBI) °c >
Subject: Fw: OCA REQUEST: Letter from Senator Blackburn to Director Patel
I-IQ needs:
Describe what the video footage is of NY apt., when the footage is from/date range of footage.
Describe what the walk through is, when it's taken, date range.
Are there Recordings of Epstein, either audio or video?
ASAC
FBI NY Violent Crime Threat
Cell:
From: (CID) (FBI) < >
Sent: Tuesday, February 25, 2025 12:38:43 PM
To: (NY) (FBI) •,: >
EFTA00161474
Cc: . (NY) (FBI) . (NY) (FBI) < =';
(CID) (FBI) <
Subject: Fw: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Good afternoon SAC
Passing this along for your situational awareness as discussed.
Thanks,
Darcy
SC Darcele "Darcy" Jones
CID - Violent Crimes Against Children Section
202-324-5898 (o)
202-384-4450 (c)
Sent: Monday, February 24, 2025 1:49:52 PM
Subject: OCA REQUEST: Letter from Senator Blackburn to Director Patel
Good afternoon,
On February 24, Senator Blackburn wrote to Director Patel regarding the Jeffrey Epstein investigation and
evidence. In her letter, she requests the following:
1. The complete flight logs from Jeffrey Epstein's private jet and helicopter.
2. Any records that were in Ghislaine Maxwell's possession that contain the names of individuals associated
with Ms. Maxwell or Mr. Epstein, including but not limited to Maxwell's "little black book."
3. All video surveillance footage from Jeffrey Epstein's Palm Beach, Florida, residence.
4. Any other documents, records, or memoranda related to the Jeffrey Epstein and Ghislaine Maxwell
matters.
If there are any materials that Senator Blackburn has requested in her letter, which we are able to provide,
please include when submitting responses. If not, please address why the materials/information cannot be
shared.
Talking points repository has an Epstein summary which may be useful to reference. It is available here: El
Epstein.
Please send responses back by COB Tuesday, March 4 with SC approval.
Best,
Management and Program Analyst
Criminal Investigative Division
Executive Staff Unit (ESU)
Desk: ea
EFTA00161475
EFTA00161476
DataSet-9
Unknown
2 pages
From: ' . (CH) (FBI)"
To: :1.1Inl i rral(CH) (FBI)"
(NY) (FBI)
Cc: (CH) (FBI)" SIMS>
Subject: FW: FW: Question about Jeffrey Epstein and
Date: Tue, 03 Dec 2019 18:36:00 +0000
Importance: Normal
how goes it. A "tip" came into our Stockholm suboffice. Turned out it was a reporter. Documented in
Sentinel. I can give more clarity on a telcal.
I miss the good of days.
F.B.I.
Legat Copenhagen
AOR includes Denmark, Sweden, Norway, Finland & Iceland (+6 EST)
Samsung
Embassy
Danish cell
On Dec 3, 2019 7:32 PM, 'I (NY) (FBI)" > wrote:
Gents,
Do you have any information regarding the inquiry below? The media is reporting "anonymous FBI agent at the American
embassy in Stockholm" claims the FBI is interested in the Crown Princess and another Norwegian citizen. Certainly if
anyone in Norway has pertinent information regarding the case we would be interested, however, we are unaware of any
current interest in Norway. Let me know if anything comes up.
Thanks,
SSA
Squad C-20
Crimes Against Children/Human Trafficking
FBI New York
office
mobile
From: (NY) (FBI)
Sent: Tuesday, December 03, 2019 11:57 AM
To: . (NY) (FBI) c >; (NY) (FBI)
Subject: Fwd: FW: Question about Jeffrey Epstein and
In? If you dont know anything about it, hit up the ALAT to see if their office put put anything or is engaged
with LE there.
EFTA00147946
On Dec 3, 2019 11:45 AM, " (NY) (FBI)" < > wrote:
See below.
Forwarded message
From: NPO
Date: Dec 3, 2019 9:16 AM
Subject: FW: Question about Jeffrey Epstein and
To: ' (OPA) (FBI)" . (NY) (FBI)"
Cc:
National Press Office
Federal Bureau of Investigation
Washington, DC 20535
I @FBI
From: Runa Fjellanger [mailto:
Sent: Tuesday, December 03, 2019 2:28 AM
To: NPO
Subject: Question about Jeffrey Epstein and
To whom it may concern,
I'm contacting you on behalf of VG, Norway's biggest newspaper, to enquire about a quote which is attributed to
an anonymous FBI agent at the American embassy in Stockholm. According to the Norwegian newspaper
Dagbladet/Se og Her, the FBI agent says: "FBI wants to speak with . We're still trying to trace
information about Epstein".
According to flight logs travelled with Jeffiaein's private jet several times, and we're
wondering if it is correct that the FBI wants to speak with in connection to Epstein? If so: Why? What
information are you hoping to discover? Have you already contacted Are there any other Norwegian
citizens or residents you wish to contact? Has there been any contact between the FBI or other American
agencies and the Norwe ian overnment, Norwegian Police Security Service or other agencies concerning
Jeffrey Epstein, or Crown Princess Mette-Marit?
If you could please get back to me at your earliest convenience, I would greatly appreciate it.
Best regards
Runa Fjellanger
Journalist
EFTA00147947
DataSet-9
Unknown
14 pages
To: Page :I of 14 202O41.23 00:02:57 (GMT) 12129373904 Front Julia Greenberg
Federal Bureau of Investigation
Records Information/Dissemination Section
170 Marcel Drive
Winchester, Virginia
Via Facsimile and Certified Mail
January 22, 2020
Dear Sir/Madame:
I am a Forensic Intelligence Analyst and a congressional consultant. I am also a paralegal
with extensive experience regarding informant practices related to the FBI and their handling of
taxpayer-funded, Top Echelon informants. I've been in documentaries, national and international
newspapers, and many television news appearances discussing informants who commit serious
crimes while working under FBI auspices. Additionally, I was an independent consultant and lead
talent on the Spike documentary, "Gone — The Forgotten Women of Ohio." That series, submitted
for a Peabody award, ran for eight episodes about, in part, murdered and missing women and
informants; corruption; and human and drug trafficking. These matters are all addressed in this
request.
This request pertains to Jeffery Epstein, born January 20, 1953 in Brooklyn, New York,
and deceased August 10, 2019 in the federal Metropolitan Correctional Center New York. A copy
of his obituary is attached to this letter. Under the Freedom of Information Act (FOIA) (5 U.S.C.
§ 552), and President John F. Kennedy Assassination Records Act of 1992, (44 U.S.C. §2107), I
request that the Federal Bureau of Investigation produce copies of any informant files, records or
materials on or pertaining to Jeffrey Epstein, including but not limited to any informant file or Top
Echelon (TE) informant file, Confidential Human Source (CHS) Reporting documents, and any
Federal Central Inmate Monitoring System (CIMS) records wherever they may be located or filed
and in whatever form or format they may be maintained.
I further request photographic copies of all photographs of Mr. Epstein. I'd like to expand
the photos, images or aerial images or any metadata pertaining thereto. With respect to electronic
surveillance materials, please provide not only the transcripts, logs, and other written materials
pertaining thereto, but also any audio or videotapes in the format in which they were recorded.
Please include copies of any agreements with Epstein, or draft copy, or proffer agreement
with Epstein and the FBI.
Include in this request all correspondence, memoranda, documents, reports, records,
statements, audits, lists of names, applications, diskettes, flash drives, letters, expense logs, and
receipts, calendar or diary logs, facsimile logs, flight logs, telephone records, call sheets, tape
recordings, video/movie recordings, notes, ticklers, numbered and lettered subfiles, 1A envelopes,
enclosures behind files,(EBF's), file covers, bulky exhibits ('Bulkier'), control files, and 'JUNE'
or 'JUNE MAIL' files or records, examinations, opinions, folders. files, books, manuals.
magazines, main discs, any mini storage files and records including and relating to mini storage
989-9779, and any records in file number storage unit files and records, archival storage unit files
and records, pamphlets, forms, closed or transferred subfiles, jottings, telephone messages,
message slips, post it notes or sticky's, drawings, charts, photographs, electronic mail, and other
documents and records or materials that refer or relate to Epstein and/or the 7 categories below in
any way, within twenty (20) business days.
4AN 3 zu2U
EFTA00172826
To: Page? of 14 202C-01-23 00:02:57 (GMT) 12129373904 From: Julia Greenberg
In conducting the search, please use all nicknames, aliases, pseudonyms, code names or
code numbers used by, or applied to, Mr. Epstein. In addition, when searching under Mr. Epstein's
name, please employ all logical buildups, breakdowns, and variations of his name.
In this request, please search the Central Records System ("CRS") for all main files and all
cross-references. This includes all index references to Epstein, including not only the Central
Records System (-cm') indices and ELSUR indices, but any informant or confidential source
indices and any indices to any office, bureau, section, division, unit or other component ofthe FBI
which may have records pertaining to him. In providing cross-reference materials, the FBI should
provide not only the initial page of the cross-referenced document and those pages to which Jeffrey
Epstein's name is indexed but also the entire document. The search of the CRS is not to be limited
to the Universal Index component ofthe CRS, but also must include searches of other components
including those specified in Negley v F R 1 658. F. Supp. 2d 50, n.3 (D.D.C. 2009).
In the search of the Electronic ("ELSUR") Indices include a search for not only those
ELSUR materials that Mr. Epstein is subject of, but also must include any "mentions" or
"overhears."
The search should include files in the FBI Director's Office, the files or folders maintained
by any FBI supervisory official in office safes, drawers or file cabinets, and the files maintained
by Assistant FBI Directors and files in the office of the SAC in Cincinnati from 1993 to January,
2020 particularly including the current and former office of both in Washington,
D.C., Cincinnati and Columbus.
The FBI search must include each field office that maintains records on Epstein, for records
that are responsive to my request. The FBI Headquarters is aware of all FBI field offices which
maintain records on Epstein, whereas I am not. Requiring me to submit requests to each of the
approximate 59 field offices would be unduly burdensome and thwart the purpose of the FOIA to
facilitate easy andprompt access to information.
Mr. Epstein's file may contain information beginning from an arrest and guilty plea that
took place in federal court for a charge of conspiring to steal U.S. Treasury Checks in 1993 or
earlier and ending August 10, 2019 the date of his death. I wish to limit the above request to the
first 500 pages which fall within the following 7 categories listed below:
1. All warrants or drafts of warrants based in whole or in part on information
submitted or provided by Mr. Epstein, including all information submitted by Epstein which was
used to support warrants or drafts ofwarrants based on information provided by him. Theserecords
are ofparticular interest because Mr. Epstein was identified as cooperating with the FBI in an FBI
document dated 9/18/08 on a child prostitution and forfeiture case against him. In this document
the case agent advised that no federal prosecution would occur as long as Epstein continued to
uphold his agreement.]
2. Any and all information related to Mr. Epstein in which the FBI identified an
associate of Mr. Epstein's criminal activities or his criminal enterprise. Please include in those
records where identification was made of a victim or an associate or recruiter of Mr. Epstein's
that left from, or were taken to, ANY locations in Kentucky, New Jersey, Ohio, or Palm Beach,
Florida. Please also include records identifying what geographical areas the victims, criminal
'This is the same type of unwarranted protection that took place with Top Echelon informant Gregory Scarpa Sr.
by his FBI handler R. Lindley DeVecchio which was identified in my case Clemente v. FBI. In addressing that case in
2005, my now deceased partner Dr. Stephen Dresch and I provided the Brooklyn District Attorney's office a
homicide referral that later led to Agent DeVecchio's Indictment of four counts of second-degree murder in 2007.
See attached.
EFTA00172827
To: Page p of 14 2020-01-23 00:02:57 (GMT) 12129373904 From: Julia Greenberg
targets, or Epstein's associates were from, such as the counties, cities, towns, suburbs, and any
unincorporated communities' name. Please also identify and release all records in the files that
mention criminal targets or associates of Epstein that held positions in public office or were
identified as attorneys or judges located in the state of Ohio. This material is important because,
during my investigation in Ohio, both on and after the series had ended and through to the present
date, several attorneys and I have communicated with senior agents at the Department of Justice
Office of Inspector General. During these communications I/we provided information related, in
part, to corruption and a human and drug trafficking ring that involves girls that were being
trafficked from or were recruited from Ohio and Kentucky and were taken to Palm Beach, Florida
and other areas of Ohio, New Jersey and other states. Our reports additionally involved
informant[s] who have admitted participation in at least two homicides. One of these murder
victims is still missing. The woman that is still missing was a client of a defense attorney who was
the subject of an interstate human and drug trafficking investigation in which the DEA provided
to and referred to the FBI that included trafficking females to Palm Beach, Florida, New Jersey
and other states throughout the U.S.
One of the subject traffickers was identified in a DEA document as being part of the
"Eubanks/Mearan organization." A subject in this same case has explained that he would meet
with the defense attorney in Columbus with guys from out of state. Some of the girls were from
Portsmouth, Chillicothe, and Columbus, Ohio and that the defense attorney was always eager to
obtain company to go with him and his buddies to Palm Beach.2
Aside from the DEA referral, in 2017 the Department ofJustice Office ofInspector General
received from the Senate Judiciary's office and me information about this and other concerns with
Ohio that was directed to the FBI's INM Division for further investigation. My colleagues and
(which included multiple attorneys) were then referred to the U.S. Attorney's Office for the
Southern District of Ohio over concerns relaxed to the public corruption aspect, which included
information on an FBI agent, a State of Ohio Bureau of Criminal Investigation Agent, a lead
detective on a federal task force for murdered and missing women, and an attorney and a judge.
The judge has since been suspended in a separate matter, and is now retired. The defense attorney
is currently under an investigation involving human trafficking and other major crimes. The
detective on the federal task force has been removed from his position with the federal authorities
and thereafter abruptly resigned from his position with the Sheriff's Office of Ross County, Ohio,
which he was employed by while working on the federal task force.
A detective who, on information and belief, possessed a fictitious New Jersey ID, was also
under both state/federal investigation and has been since retirement in 2019. See Attached Letter
to Ohio Auditor's Office. The U.S. Attorney's Office for the Southern District of Ohio is
scheduling an upcoming appointment to further discuss matters related to potential physical
evidence in the above related matter of human trafficking, public corruption and homicide. The
records that I am requesting here will shed light on the government operations that are flawed in
which it appears to have essentially provided a ripe opportunity for more victims to be victimized
and sexually exploited by informant[s], and those who hold a position in public office in which
these victims and their communities were reliant upon for their safety and the proper application
of the law.
2 this was a sealed DEA warrant application that was made public information by Cincinnati Enquirer on 3/21/19
and again by USA today in the same year. https://wws.v.cincinnati.comfin-depth/news/2019/03/21/tex4rafficking-
trapped-and-trafficked-portsmouth-ohio/21339816002/
EFTA00172828
To: Page 4 of 14 2020-01.2300:02:57 (GMT) 12129373904 From: Julia Greenberg
3. All records pertaining to or referencing Portsmouth, Ohio Attorney Michael
Mearan. Also include records pertaining to or referencing William Marshall or Mark Eubanks.
4. All records in any informant file in chronological sequence, commencing with the
present year 2020 through to the earliest date.
5. All records that has FBI employee name, or codename, or
signature, or initials on them pertaining to any Epstein investigation related to Ohio or mentioning
Ohio, New York, New Jersey, or Palm Beach, Florida. Many cases that I, and law enforcement
officials, have requested the FBI to investigate issues related to FBI informants and their handlers'
informant pr ces were re ularly dismissed by and the offices in which she was
employed. ' former office was located in Cincinnati, where she was a Special
Agent in Charge (SAC). At the time, she was an SAC over one of the FBI agents and a BC! agent
that the DOJ 1G's office submitted to the FBI's INSD division (a division in which she had
previously been employed) for further investigation. But not one witness that agreed to cooperate
with the FBI officials, including former and current law enforcement officials, was contacted by
the FBI. Moreover, one local low-level informant was willing to provide the location of the body
of a woman who remains missing, but the Ohio Bureau of Criminal Investigation Agent who was
on the federal task force. The FBI Agent chose to never contact the informant, who was a
participant in the woman's homicide. The lead detective on that case was the detective that was
also on the federal task force with the FBI and BO Agent mentioned above, and he has since
resigned from his position after the discovery of misconduct related directly to him. The missing
victim was a client of the defense attorney who was under investigation for trafficking women to
Palm Beach, Florida and other states. I suspect these documents' release will shed light on the
FBI's failures to protect murdered and missing women in Ohio, and those trafficked to Palm
Beach, Florida, New Jersey and other states. One of Jeffrey Epstein's victims has been recently
reported to say that she was taken to one of Epstein's associates homes, in Ohio, and assaulted
there. A lawsuit is pending on this issue.
6. All records pertaining to Epstein victims associated in any way with Ohio or
pertaining to Ohio, Kentucky or New Jersey that were taken to Palm Beach, Florida or were
brought from Palm Beach, Florida to other states or countries including which states or countries
the victims were brought to by Epstein or his associates.
7. All records pertaining to any FBI internal investigations related to Epstein, or
Epstein and Ohio, whether located in the FBI Inspection Division (FBI-INSD), National and
Transnational Organized Crime section, Office of Professional Responsibility, Public Corruption
Division, Units, or Offices, Violent Crime Divisions, FBI Cincinnati Field Division (White Slave
Trafficking investigation) FBI Cincinnati Field Division Human trafficking investigations, FBI
Detroit Field Division Extortion Investigation, FBI Cincinnati Field Division Mexican Drug
Trafficking Organization investigation files, FBI Cincinnati Field Division Violent Gang
investigation or DEA Cincinnati Resident Office Investigation referrals to the FBI; and also FBI
civil litigation division files or records of any kind whatsoever, and Counter-Intelligence Sections.
If after the 500-page limit has been reached other informant materials remain, please advise
us of the approximate number of pages they comprise.
Please also advise us that you have placed my request in the "short hit" queue and inform
us of an approximate date when I will begin receiving the requested records.
If any responsive record or portion thereof is claimed to be exempt from production under
FOIA, sufficient identifying information (with respect to each allegedly exempt record or portion
EFTA00172829
To: Popp of 14 2020-01-2300:02:57 (GMT) 12129373904 From: Julia Greenberg
thereof) must be provided to allow the assessment of the propriety of the claimed exemption.
Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir 1973), cert denied, 415 U.S. 977 (1974). Additionally,
any reasonably segregable portion of a responsive record must be provided to me after redactions
of any allegedly exempt material, as the law requires. 5 U.S.C. § 552(b). In order to help to
determine my status for purposes of determining the applicability of any fees, you should know
that I am a
I am willing to pay fees up to $50.00.If the fees will exceed this amount, please inform me
before fees are incurred. I can be contacted at Angelacletnente forenAing@grnsiii ram, if necessary
to discuss any aspect ofthis request. Under 5 U.S.C. § 552(a)(4XAXiii), I hereby request a full fee
waiver for public interest. The materials that I seek will shed significant light on government
operations and activities with informant practices similar to those I have already successfully
helped to correct flaws. See, for example,DOS-IG Special Report from September 2005, regarding
in pan a case I was involved in related to Top Echelon Informant Gregory Scarpa Sr. and his
handler Lindley DeVecchio. This was information that I provided to the U.S. House of
Representatives that was later submitted by them to the Department of Justice Office ofInspector
General (DOS IG). The DO3-1O also used my case as an example in their Special Report.
Similarly, the materials requested here will, among other things, shed light on (1) what the FBI
knew about Epstein's criminal activities while he was serving as an FBI informant (2) the extent
to which Epstein's relationship to the FBI corrupted the system of justice; (3) how many victims
were identified after the FBI chose to not prosecute Epstein in 2008; (4) whether Epstein was
working and conspiring with others in public office who facilitated his conduct, by among other
things, contacting victims and scheduling or facilitating sexual encounters with Epstein or his
acwiates (some of whom are or may currently be under state and federal investigation in
geographical areas such as Scioto, Ross and Franklin Counties, Ohio), especially as related to
interstate human trafficking and murder. I have already been directly investigating and have been
in direct communication with the U.S. Attorney's Office Southern District of Ohio, Chief of the
Criminal Division regarding many of the human trafficking cases in Ohio. I was
directed to Mr. after the DOJ-1G referred some of these cases over to the FBI's INSD for
review.
I am capable of disseminating the information to the public. Indeed, prominent members
of the news media have indicated their interest in covering not only the disclosure of any records
pursuant to my request but the filing of Freedom of Information lawsuit to obtain them. I look
forward to receiving the requested documents and a full fee waiver within twenty business days.
Please address any further correspondence to this request to both me and to my attorneys
Julia Greenberg, Jim Lesar, and Jay Hurst at the following addresses:
Jay Hurst
1890 Star Shoot Parkway
Suite 170, PMB 371
Lexington, Kentucky 40509
Jim Lesar
930 Wayne Avenue
Unit 1111
Silver Springs, MD 20910
EFTA00172830
To: Page.6 of 14 2020-01-23 00:02:57 (GMT) 12129373904 From: Julia Greenberg
Julia Greenberg
160 Broadway
Floor
New York, New York 10038
EFTA00172831
To' Page 7 of 14 2020.01-23 00:02:57 (GMT) 12129373904 Iron Julia Greenberg
...0say-TX4)
FEDERAL BUREAU OF INVESTIGATION
•
Date: 09/18/2008
,Mtn: SAl
P8-i, PUCRA
tw
Drafted By: I acm
Case ID I:veCE-M14-108.062-FF E-Feastkeac0
sR
Title: GENERAL FORFEITURE MATTERS
JEFFREY EPSTEIN.
!STA - CHILD PROSTITUTION
Synopsis: ..Perfilest closing - off forfeiture Subfile FF.
TnvestlqatiCal has revealed that,
c.1 Fl- IS
On 9111/08, case agent advised writer that Epstein
is currently being prosecuted by the State or:Florida and is
complying with all conditions Of his plea with. the State of
Florida. - 5pstein -baoelso provided information to tho FBI as
.agreed upon. Case agent advised that no federal prosecution
will occur in this matter as long as Epstein continues to
• uphold his a4reemanc with the State -of. Florida: Case. agent
-alsoadvised.that no further forfeiture assistance will be
)required for thie:caSe. Case.ogent is requested to contact
writer in the event this matter moves forward on a tederal
leve3.
•;_e Oloc no farther in-Fr-Aura related action is
deemed necessary jr. this matter, It -im requested that subfile
IF ho closed:
EFTA00172832
To: Paget of 14 2020-01-2300:02:57 (GMT) 12129373904 From: Julia Greenberg
ANGELA CLEMENTE & ASSOCIATES
'CONGRESSIONAL CONSULTING/FORENSIC INTELLIGENCE OFFICES
P.O. Box 90I Rio Grande, NJ 03242 *Telephone 609-972-3162 AngclacIrmeale.foreosicarNmail.eom
January 17, 2019
State of Ohio Auditor's Office
Mr. David Yost (Corrected Version dated 1/17/19)
Public Integrity Assurance
88 East Broad Street
P.O. Box 1140
Columbus, Ohio 43215
Sent via Certified Mail # 7018 0360 0001 8355 1082
HIGHLY CONFIDENTIAL
Mr. David Yost:
This letter is to notify your office about several very serious unconfirmed allegations and
information that I've been made aware of regarding the Ross County Sheriff's Office and
official[s] within that office and to request an immediate investigation to determine its accuracy
and take action (if confirmed) where it is necessary. These reports also extend into other offices
in Ross County including the Ross County Prosecution office, specifically regarding the risk of a
significant conflict of interest that may arise if it is involved in any capacity in investigating
these specific allegations.
The allegations and information involve a detective's alleged conduct while he was on duty
working both regular and overtime hours. The official is John Winfield who was a detective from
the Ross County Sheriff's Office and the Sheriffs lead detective on a local, State and Federal
Task Force of the murdered and missing women of Ross County, which included victim's
Charlotte Trcgo, Tameka Lynch, Timberly Claytor, Tiffany Sayre, and Wanda Lemons. It may
also include victims Megan Kellough, Clianelle Watkins, and Angela Dyer.
On the State and Federal Task Force, Detective John Winfield was working with Ohio Attorney
General's Bureau of Criminal Investigation (Agent Larry McCoy and Ryan Scheiderer). It is my
understanding that he was also federally deputized to work with the Federal Bureau of
Investigation under Agent David Knight. BC( Agents Larry McCoy and Ryan Scheiderer were
also deputized to work on the Federal Task Force. It is reported that Ross County Prosecutor
Matthew Schmidt was involved with the Task Force and was reported to have met with them
regularly.
EFTA00172833
To: Page9 of 14 2020-01-23 00:02:57 (GMT) 12129373904 From: Julia Greenberg
The residents of Ross and Scioto Counties and the families of the murdered and missing women
in both counties signed a petition last year for Ross County Prosecutor Matt Schmidt and Judge
Ater to be removed from their cases for reasons of bias and their legitimate concerns that Judge
Michael Ater and Prosecutor Matt Schmidt provided leniency to and potentially protected an
alleged longtime informant, Earnest "Dollar Bill" Moore and because they felt their casts were
not being properly investigated or addressed. The community and victim's families petitioned
the U.S. Attorney General to assign a special prosecutor to remove Judge Michael Ater and
Prosecutor Matt Schmidt. This petition received over 2000 signatures. Scioto County citizens
also requested that a special prosecutor be assigned on their cases citing similar concerns.
The missing women's task force was comprised of the following entities and individuals:
Ross County Sheriff's Chief Deputy T.J. Hollis- He led the local task force.
Ross County Sheriff's Office Detective John Winfield- Lead detective on the missing women's
task force. (Federally Deputized)
Chillicothe Police Department
Federal Bureau of Investigation- Agent David Knight (SAC- a)
Attorney General's Office Bureau of Criminal Investigation- Agent Larry McCoy and Ryan
Scheiderer (Federally Deputized)
The current unconfirmed allegations and information include the contents below:
Detective John Winfield received approximately 513,000 in overtime compensation, portions of
which were federal funds provided to the Ross County Sheriffs office where he was employed.
Because he was the lead detective on the missing women's cases, these allegations and reports
require serious review for both criminal and civil action and demand a very thorough
investigation.
It is reported that while he was compensated, Detective Winfield used company equipment (i.e.
his official vehicle) and falsely reported that he was working when he was not. He was also
engaged in an extramarital affair with another deputy from the same office, Ross County
Sheriff's Deputy Jena Horiack. His conduct allegedly caused hatin to that deputy as she was a
victim of physical abuse, pregnant and was reported to have allegedly lost an unborn baby. She
has since left her employment at the Ross County Sheriff's Office and was subsequently offered
employment by the Ross County Prosecution office allegedly as a result of the circumstances
that Detective Winfield placed her in. Detective Winfield's behavior was reported to Mike
Preston from the Ross County Sheriff's Office and it is my understanding that Sergeant Lamborn
filed charges on him. He was then placed on administrative leave but stayed on the roster.
Ohio citizens who are taxpayers help fund these local, federal and state entities who are in place
to protect and preserve life and they have every right to know where and how their tax dollars are
2
EFTA00172834
To: Page•10 of 14 2020-01-23 00:02:57 (GMT) 12129373904 From: Julia Greenberg
being spent. The reports and allegations additionally include that the Ross County Prosecutor's
office "quietly" worked out a deal that Detective Winfield was to attend a six-month inpatient
rehabilitation program in Kentucky where he was allegedly ordered to be treated for sex, drug,
and alcohol abuse. However, he left approximately two months early, immediately violating the
"leniency" that he was being given and subsequently committed a fourth-degree felony of
criminal trespass on his wife's property.
After receiving this information, i checked for verification purposes which showed the court
docket sheet displaying a criminal trespass charge on 9/26/2018 filed by his wife Michelle
Winfield. The violation dine was 9:10. Ticket number was SI983 and was visible on the court
docket as a 4th degree misdemeanor Section 2911.21. The case number was CRB 1803360.
Detective Winfield's date of birth is 3-5-82. The case was in the Chillicothe Municipal Court.
There is another pending case which is most likely a result of the above related incident. That
case is 18 DR 000417. The case is a Dissolution with Children case that is currently being
handled under Judge Michael Ater. This case is located with the Ross County Court of Common
Pleas. Judge Ater's wife works for the Ross County Prosecutor's Office under former Prosecutor
Matthew Schmidt and now it is alleged that Detective Winfield's victim (his former mistress)
also works with the Ross County Prosecutor's office. Judge Matthew Schmidt is now working
with Judge Michael Ater. Former Prosecutor Matthew Schmidt's wife works for the Ross
County Sheriff's Office.
On a related note I have received numerous reports that Detective Winfield did not properly
handle information from willing witnesses related to the murdered and missing women's cases.
He did not act on information from those reporting parties or others nor did he follow up on
information that was provided by people who contacted him directly or who contacted the
Sheriff's office or others where he was the lead detective and they felt that he did not investigate
the information he received.
The implications of these allegations arc significant because the perpetrator[s] have not been
arrested and because it raises the possibility if these charges are verified that some of these
deaths could have been prevented if he had followed up on the information received or spoke to
the reporting parties who could have provided information and/or physical evidence.
Below is a list of the information and allegations that Detective Winfield was allegedly engaged
in while using his state and federal authorized time on duty that were not work related. These
allegations have not been verified or confirmed and should be investigated:
• Theft in office
• Fraud
• Misappropriation of funds (fraudulent use of local, state, and federal tax dollars)
3
EFTA00172835
To: Page11 of 14 2020-01-23 00:02:57 (GMT) 12129373904 Front Julia Greenberg
• Drug and Alcohol abuse
• Assault
• Insubordination
• Dereliction of Duty
lam sure the community does not care about the allegations of his extramarital affairs with
another deputy, as that is a personal issue that should not be disclosed. However, they do care
about his conduct as the lead detective on a federal task force for the murdered and missing
women; especially if any deaths could have been prevented if he had followed up on witness
reports or if he was actually working while he was supposed to be on duty as an official with the
task force. Equally concerning is that federal funds and tax payer dollars may have been
misappropriated to this detective in spite of his problematic conduct, including the allegations of
theft in office and other misconduct which, if verified, should have led to criminal charges.
The following questions regarding Detective Winfield arise:
1. Were any emergency calls or any calls missed while he was on duty but not actually working
that may have placed any lives in jeopardy?
2. Were any lives lost because he did not act on any leads or information that was provided by
citizens on the murdered and missing women's cases?
3. Who investigated Detective Winfield's actions? Were they a biased party? What were the
consequences of that investigation since it is reported that he terminated the alleged mandatory
rehabilitation early?
4. Why was he reassigned a new position in Waverly after allegedly being demoted by the Ross
County Sheriff's Office in spite of the fact that he allegedly prematurely left his ordered
mandatory rehabilitation in Kentucky and had a trespass complaint against him?
5. Were the funds that he received in overtime and on the clock refunded if he was not working
during the hours that he reported he was working?
6. Were the federal authorities notified that the funds were potentially misappropriated?
7. Has the Internal Revenue Service been contacted about the theft in office?
8. Has the Department of Justice Office of Inspector General been notified since he was on the
federal task force as the lead detective fur the murdered and missing women's cases and criminal
acts have been allegedly committed?
4
EFTA00172836
To: Page.12 of 14 2020-01.23 00:02:57 (GMT) 12129373904 From: Julie Greenberg
9. Has an official government assessment been made as to how much money was received in a
fraudulent manner that he claimed on his overtime and regular work shift specifically for the
murdered and missing women's cases?
10. Were the BCI Agents that he worked with regularly, Agents Larry McCoy and Ryan
Scheidercr, involved in any capacity with Detective Winfield for the allegations listed herein?
Finally, Detective Winfield is also reportedly a relative of one of the alleged killers of at least
two of the murdered and missing women and should have never been placed in that position. He
had already been reported to federal and congressional offices in Washington for other conduct
that was problematic and questionable.
It is with this information that this request is made to (1) conduct a full independent
investigation on these allegations (2) obtain the records of funding that has been expended to
Detective John Winfield when he reported that he was on duty both as a federal task force officer
and as a Ross County Sheriff's Deputy and (3) determine whether any deaths might have been
prevented if he had followed up on any evidence or with any witnesses that claimed to have
reported or attempt to report information to him.
If you have any questions, please feel free to contact me at your convenience.
Respectfully Submitted,
Angela Clemente
cc: Internal Revenue Service
Department of Justice Office of Inspector General
U.S. Attorney General
5
EFTA00172837
To: Page.13 of 14 2020-01-23 00:02:57 (GMT) 12129373904 From: Julia Greenberg
Private pathologist questions whether Jeffrey
Epstein died by suicide; medical examiner
stands by conclusion
Kevin Johnson Kristine Phillips
USA TODAY
WASHINGTON — New York City's chief medical examiner said there's no need for a
second investigation into Jeffrey Epstein's death after a pathologist hired by the family argued
that injuries to the disgraced financier point to homicide, not suicide.
Epstein, 66, died while awaiting trial on federal sex trafficking charges. He was found
unresponsive in his Manhattan jail cell early on Aug. 10.
New York City Chief Medical Examiner Dr. Barbara Sampson later mind that Epstein died of
suicide by hanging and refined conspiracy theories that foul play was involved.
Michael Baden, a former New York City medical examiner who was hired by Epstein's brother,
said in a Fox & Friends interview Wednesday morning that broken bones in Epstein's
neck indicate a "huge amount of pressure" was applied.
"There were findings that are unusual for suicide by hanging and more consistent with ligature
homicidal strangulation," Baden said.
Curiosity around one of those broken neck bones — the hyoid — has been at the center of theories
about Epstein's death, which President Donald Trump has promoted.
News outlets reported in August that Fpstein suffered broken hones in his neck But The
Washington Post, which first reported on the injuries, cited experts saying curh hrrakc ran orenr
in_people_who hang _themselves, particularly if they arc older.
In a statement Wednesday, Sampson said she stands by her conclusion that Epstein died by
suicide.
"Our investigation concluded that the cause of Mr. Epstein's death was hanging and the manner
of death was suicide," she said. "The original medical investigation was thorough and complete.
There is no reason for a second medical investigation by our office."
Sampson said her office continues "to share information around the medical investigation with
Mr. Epstein's family, their representatives, and their pathology consultant."
Baden, a Fox News contributor, said he does not know what work federal investigators have
done on Epstein's death, but he called on officials to investigate further. He said the ligature that
EFTA00172838
Pages 14 of 14 2020-01-23 00:02:57 (GMT) 12129373904 From: Julie Greenberg
was found wrapped around Epstein's neck was fashioned from bed sheets and would have
contained DNA evidence.
Baden served as New York City's medical examiner for one year, beginning in 1978.
Prosecutors had alleged Epstein "sexually exploited and abused dozens of minor girls" at his
homes in Manhattan and Palm Beach, Florida, and at other locations from at least 2002 to 2005.
After Epstein's death, Attorney General William Barr ordered multiple investigations focusing
on the operations at Manhattan's Metropolitan Correctional Center, which has been plagued with
staffing shortages. Those investigations arc ongoing.
Fcdcrai authorities have been examining whether guards assigned to Epstein's unit slept through
mandatory checks on his cell in the hours before he was found dead, and whether the guards
falsified logs accounting for their time on duty.
Epstein had been placed on suicide watch after he was found semiconscious with marks on his
neck just three weeks earlier, but he was removed from monitoring shortly after.
At the time of Epstein's suicide, there were more than 30 staff vacancies at the facility, said
Serene Gregg, local president of the prison workers' union. Prison officials regularly assigned
civilian staffers to work guard duty to plug unfilled officer positions, she said.
Ten of the 18 staffers who reported for duty on the midnight-to-8 a.m. shift — the one during
which Epstein was found dead — were working overtime, according to federal prison records. On
the previous shift, 4 pan. to midnight, six of the 20 staffers were working overtime.
Contributing: Grace Muck
EFTA00172839
DataSet-9
Unknown
11 pages
#291874/mep IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800)OOO(MBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
REVISED
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
COMES NOW the Counterplaintiff, BRADLEY J. EDWARDS, by and through his
undersigned attorneys and hereby lists his exhibits for trial as follows:
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
EXHIBITS EXPECTED TO BE USED
I. All applicable criminal statutes
2. All applicable Florida Statutes
3. All applicable Rules of Evidence
4. Video of Jeffrey Epstein's home and route from victim to Epstein's
home
5. Order confirmation from Amazon.com for purchase of books
"SM 101: A Realistic Introduction," "Slave Craft: Roadmap for
Erotic Servitude-Principles, Skills and Tools" and "Training Miss
EFTA01140114
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 2 of I I
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Abernathy:
A Workbook for Erotic Slaves and Their Owners"
6. Non-Prosecution Agreement
7. Jane Doe 102 Complaint
Messages taken from message pads found at Epstein's home
8.
Documents related to Jeffrey Epstein produced by Alfredo
9
Rodriguez
Jeffrey Epstein flight logs
10
Jeffrey Epstein phone records
II.
Sarah Kellen's phone records
12
Jail Visitation Logs
13.
Jeffrey Epstein's probation file
14
All probable cause affidavits related to criminal investigation
15
of Jeffrey Epstein
All evidence, information and documents taken or possessed
16
by FBI related to criminal investigation of Jeffrey Epstein
Victims' statements to the FBI related to criminal investigation
17
of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being
18.
executed
Application for Search Warrant of Jeffrey Epstein's home
19
Complaint Jane Doe v. Epstein and all subsequent Amended
20
Complaints
All records of homes, properties, bank accounts and any and
21
all records related to Jeffrey Epstein's assets
Jeffrey Epstein's passport (or copy)
22
Jeffrey Epstein's driver's license (or copy)
23.
EFTA01140115
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 3 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
List of corporations owned by Jeffrey Epstein
24
All documents evidencing relationship between Jeffrey Epstein
25
and Jean Luc Brunel
All documents evidencing relationship between Jeffrey Epstein
26
and MC2 or any modeling agencies
27. Yearbooks of Jane Doe
2002 Royal Palm Beach High School Year Book
28.
2001 Royal Palm Beach High School Year Book
29
2003 Palm Beach Gardens High School Year Book
30.
Affidavit and Application for Search Warrant on Jeffrey
31.
Epstein's home
Tape recording or transcript of recording of conversation
32
between Jeffrey Epstein and George Rush
Notepads found in Jeffrey Epstein's home and/or during trash
33
pulls outside of his home during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey
34.
Epstein
All documents related to Jeffrey Epstein's 6/30/08 conviction
35.
Jeffrey Epstein's criminal plea colloquy
36.
37. Public records from the Department of Corrections related
to Jeffrey Epstein
Records from the Florida Department of Law Enforcement
38.
related to Jeffrey Epstein
All statements made by Jeffrey Epstein
39.
List of properties and vehicles in Larry Visoski's name
40
All of Jeffrey Epstein's Responses to Requests for Production,
41.
Requests for Admission, Answers to Interrogatories in this matter,
and 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
EFTA01140116
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 4 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
All discovery related responses of Jeffrey Epstein in this matter
42.
and 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
Jeffrey Epstein's Answers and Affirmative Defenses in
43.
all civil cases against him
All Complaints in which Jeffrey Epstein was a plaintiff
44.
or defendant
Jeffrey Epstein's Deposition testimony and discovery responses
45.
in this case and 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
Jeffrey Epstein's Deposition testimony and discovery responses
46
in State Court cases LM v. Jeffrey Epstein, Case No.
502008CA028051XXXXMB AB and E.W. v. Jeffrey Epstein,
Case No. 502008CP003626XXXXMB
Jeffrey Epstein Deposition Testimony and discovery responses
47
in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No
502009C A040800XXXXMBAG
Any and all newspaper articles, online articles or publications
48
related to Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets
49
Video footage (DVD) of walk through site inspection of Jeffrey
50.
Epstein's home.
Photos of all of Jeffrey Epstein's properties, cars, boats and planes
51
Prob Affidavits prepared against Jeffrey Epstein
52.
and
Audio tape of Haley Robson
53.
Photographs, videos and books taken in the search warrant
54.
of Jeffrey Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations
55.
to law enforcement
Victim Notification Letter from US Attorney's Office to
56.
Victim
EFTA01140117
Edwards adv. Epstein
Case No.: 502009CAC140800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 5 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Expert Dr. L. Dennison Reed's Report of Victim
57.
Palm Beach Police Department Incident Report dated 4/20/06
58
All reports and documentation generated by Palm Beach Police
59. Department related to Jeffrey Epstein
All Witness Statements generated by Palm Beach Police
60.
Department relating to Jeffrey Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private
61. plane flight logs
Passenger lists for flights taken by Jeffrey Epstein
62
Letter from Jeffrey Epstein to Alberto Pinto regarding house
63. island project
Jeffrey Epstein's bank statements
64
Jeffrey Epstein's tax returns
MC2 mails involving communications of Jeffrey Epstein,
65. Jeff Fuller, Maritza Vasquez, Pappas Suat, Jean Luc Brunel
and Amanda Grant
DVD of plea and colloquy taken on 6-30-08
66.
Transcript of plea and colloquy taken on 6-30-08
67.
Massage Table
68.
Lotions taken from Jeffrey Epstein's home during search
69 warrant
Computers taken from Jeffrey Epstein's home during search
70. warrant
71. Vibrators, dildos and other sex toys taken from Jeffrey
Epstein's home during search warrant
72. No Contact Orders entered against Jeffrey Epstein
Criminal Score Sheet regarding Jeffrey Epstein
73
74. Documents evidencing Jeffrey Epstein's Community
EFTA01140118
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 6 of II
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED
TED DESCRIPTION OF EXHIBITS
Control and Probation
75. Jeffrey Epstein's Sex Offender Registration
Jeffrey Epstein's Booking photograph
76.
CAD calls to 358 EL BRILLO WAY, PALM BEACH
77.
FL 33480
List of Jeffrey Epstein's House contacts
78
Documents related to Jeffrey Epstein's investments
79.
Letter from Chief Michael Reiter to Barry Krischler
80
List of planes owned by Jeffrey Epstein
81.
Letter from Guy Fronstin to Assistant State
82
Attorney dated 1-11-06
Letter from Guy Fronstin to Assistant State
83
Attorney dated 1-13-06
Letter from Guy Fronstin to Assistant State
84.
Attorney dated 2-17-06
Letter from Guy Fronstin to Assistant State
85.
Attorney dated 4-6-06
Letter from Guy Fronstin to Assistant State
86
Attorney dated 4-10-06
Letter from Goldberger dated 6-22-06
87
All subpoenas issued to State Grand Jury
88.
Documents related to the rental of a vehicle for Vanessa Zalis
89
Ted's Sheds Documents
90.
Documents related to property searches of Jeffrey Epstein's
91
properties
Arrest Warrant of Sarah Kellen
92
Police report regarding Alexandra Hall picking up money
93.
dated 11-28-04
EFTA01140119
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 7 of I I
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
List of Trilateral Commission Members of 2003
94.
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
95.
Guy Fronstin letter dated 4-17-06
96.
Jeffrey Epstein Account Information
97.
Jeffrey Epstein Criminal Closeout Sheet
98.
Jeffrey Epstein Polygraph Test and Results
99
Victim's GED testing information and results
100.
JEGE, Inc. Passenger Manifest
101.
Hyperion Air Passenger Manifest
102.
Flight information for Dana Burns
103.
Passenger List Palm Beach flights 2005
104.
Jeffrey Epstein notepad notes
105.
Pleadings of lane Doe 1 and 2 v. US case
106.
Jeffrey Epstein 5h Amendment Speech
107.
Reiter letter to Krisher dated 5-1-06
108.
Jail receipts of Jeffrey Epstein
109.
Alexandra Hall Police Report dated 11-28-04
110.
Compulsory Medial Examination of victim, CMA
III.
Victim's school records and transcripts
112.
Victim Notification letter dated 7-9-08
113.
EFTA01140120
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 8 of 11
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Victim's employment records from MOP
114
Police report of Juan Alessi theft at Jeffrey Epstein's home
115.
Victim's Medical Records from Milton Girls Juvenile Facility
116
Victim's Medical Records from Dr. Randee Speciale
117
Victim's Medical Records from Wellington Regional Hospital
118
Victim's Medical Records from St. Mary's Medical Center
119
Victim's Medical Records from United Health
120
All surveillance conducted by law enforcement on Jeffrey
121. Epstein's home
Emails received from Palm Beach Records related to Jeffrey
122
Epstein
All items listed on the Palm Beach Police Property Report Lists
123
All items taken in the execution of the search warrant of
124
Jeffrey Epstein's home: 358 EL BRILLO WAY,
PALM BEACH FL 33480
All copies of convictions related to Jeffrey Epstein
125.
Jeffrey Epstein criminal records
126
All documents produced by Palm Beach Police Department
127. prior to the deposition of Detective Recarey
Photographs of all persons listed on Victims' Witness Lists
128
Statements, deposition transcripts, videotaped depositions
129
and transcripts taken in connection with this and all
related cases and exhibits thereto
Any and all expert witness reports and/or records generated
130. in preparation for this litigation by any party to this cause
Curriculum vitaes of any and all listed experts
131
Curriculum vitae of Dr. Ryan Hall
132.
EFTA01140121
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 9 of I I
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Any articles or publications of Dr. Ryan Hall
133.
Any articles or publications of Dr. Richard Hall
134.
Any articles or publications of Dr. L. Dennison Reed
135.
All items and documentation review by Dr. L. Dennison Reed
136.
Transcript and video (DVD) of IME of Victims
137
All exhibits to Dr. L. Dennison Reed's Deposition
138
All exhibits to Dr. Richard Hall's Deposition
139.
All items and documents reviewed by Dr. Richard Hall
140.
All items and documents reviewed by Dr. Ryan Hall
141
All exhibits listed on the Epstein's Exhibit List
142
Demonstrative aids and exhibits including, but not limited to,
143. anatomical charts, diagrams and models, surveys, photographs
and similar material including blow-ups of the aforesaid items.
144. mo rtality-tables
Edwards' reserves all objections to Epstein's Exhibits
145
Edwards reserves the right to supplement and/or amend his
146. Exhibit List
By listing an Exhibit, Edwards is not waiving his right to
147. object to same at trial and does not waive their right
to amend same.
All exhibits listed by Epstein subject to Edwards' objections.
148
All pleadings and attachments in the action under the Crime
149. Victims Rights Act prosecuted by Bradley Edwards
on behalf of victims of Epstein's criminal molestations.
All attachments to Edwards' Motion for Summary Judgment.
150.
EFTA01140122
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page I 0 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
All time records and hourly billing documentation produced
151
in discovery.
All deposition testimony and discovery responses by Epstein
152
submitted in this action.
All pleadings filed by Epstein in the Rothstein
153.
bankruptcy proceeding.
All submissions by Epstein in connection with the Rothstein
154.
deposition.
All Settlement Agreements between Epstein and victims
155. of his sexual molestation.
Plaintiff reserves the right to amend this list.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-
Service to all counsel on the attached list, i 2014.
Jack S ola/
law.com; [email protected]
Fl rid tar No.: 169440
ear• Denney Scarola Barnhart & Shipley, P.A.
9 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorneys for Bradley J. Edwards
EFTA01140123
Edwards adv. Epstein
Case No.: 502009CA040800)ODOCIVIBAG
REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 11 of I I
COUNSEL LIST
Jack A. Goldberger, Esquire
jgoldberger®agwpa.com;
smahoney®agwpa.com Phone: (954)-467-6767
Atterbury, Goldberger & Weiss, P.A. Fax: (954)-467-3599
250 Australian Avenue South, Suite 1400 Attorneys for Jeffrey Epstein
West Palm Beach, FL 33401
Phone: (561)-659-8300 Marc S. Nurik, Esquire
Fax: (561)-835-8691 [email protected]
Attorneys for Jeffrey Epstein Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Bradley J. Edwards, Esquire Fort Lauderdale, FL. 33301
staff.efile®pathtojustice.com Phone: (954)-745-5849
Farmer, Jaffe, Weissing, Edwards, Fistos & Fax: (954)-745-3556
Lehrman, FL Attorneys for Scott Rothstein
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire
Phone: (954) 524-2820 tonja®tonjahaddad.com;
Fax: (954) 524-2822 Debbie®Tonjahaddad.com
Tonja Haddad, P.A.
Fred Haddad, Esquire 315 SE 7th Street, Suite 301
[email protected]; Fort Lauderdale, FL 33301
haddadfm®aol.com Phone: (954)467-1223
Fred Haddad, P.A. Fax: (954)-337-3716
One Financial Plaza, Suite 2612 Attorneys for Jeffrey Epstein
Fort Lauderdale, FL 33394
EFTA01140124
DataSet-9
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6 pages
-1 of 6 - OFFICIAL RECORD
FD-302(Rev.54.10)
FEDERAL BUREAU OF INVESTIGATION
Wteofemq 04/23/2020
, DOB , was interviewed at
Present for the interview was
After being
advised of the identities of the above listed individuals and the nature of
the interview, provided the following information:
GYPSY connected to JEFFREY
EPSTEIN. thought GYPSY may have worked for EPSTEIN in getting EPSTEIN
girls. Years later, GYPSY told that EPSTEIN was sending him money.
GYPSY made videos on how to massage.
went on a trip to Africa with EPSTEIN and BILL CLINTON. •
was living wanted to introduce
to EPSTEIN. This was approximately in early 2002; was 17 years
old. EPSTEIN was at the Bel Air Hotel; and drove there
together, and arrived to his suite. EPSTEIN was in his room fully clothed.
started massaging EPSTEIN's feet and was invited to massage
his other foot. EPSTEIN asked questions about her life and
background. believed that GHISLAINE MAXWELL and were
also there.
After this, phone calls shortly followed. thought he may have been
LESLEY (known to law enforcement as LESLEY GROFF) who may have connected the
call from EPSTEIN. This was usually how the calls worked.
flew to New Mexico. was at EPSTEIN's ranch with MAXWELL,
, and other girls. MAXWELL took horseback riding. told
MAXWELL all about herself. did not have a distinct memory of telling
Investigation on 11/21/2019 at United States (In Person)
File SOD—NY-3027571 Date Mafia 03/30/2020
by
This document contains neither recommendations nor conclusions of the FRI. It is the progeny of the FBI and is loaned to your agency; it and its contents are not
to be distributed outside your agency.
3501.054-008
CONFIDENTIAL Page 1 of6
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Continuation of FD-302 of (U) Interview of on 11.21.19 ‘ cm 11/21/2019 ,page 2 of 6
them her age, but they knew how old she was. The first assault happened in
New Mexico; EPSTEIN and were both there in the room. EPSTEIN took
them in the Hummer and offered to let drive, telling that he
could replace it easily. remembered visiting different cabins. This
trip lasted a couple of days.
The next interaction had with EPSTEIN was phone calls. knew
that she had also visited EPSTEIN's properties in Palm Beach, the Virgin
Islands, and New York. In approximately 2002, flew from
to meet EPSTEIN in New York then they flew to Florida then to the island
then back to Florida. thought she then flew back on her own to III
on the flight logs for EPSTEIN's plane.
In every one of EPSTEIN's properties, was abused by EPSTEIN.
The next interaction with EPSTEIN was when she flew from to Paris
in approximately January 2003.
was working . EPSTEIN encouraged
her and said he would pay for
EPSTEIN encouraged to
; EPSTEIN paid for it. These conversations started when first
met EPSTEIN. EPSTEIN had agreed to pay for her before
trip to New Mexico.
The first time met EPSTEIN, they took a trip to Venice Beach.
MAXWELL, , and other girls, whose names did not
recall, were all there. The other girls picked out their own things, while
EPSTEIN picked out things for her, including an African mask and a sweater.
had bought books for and EPSTEIN reimbursed her
for everything she bought. EPSTEIN bought
LESLEY facilitated all of travel. thought she coordinated
with LESLEY via phone. This was something and EPSTEIN would discuss
and then she would get a call from LESLEY.
On the long trip was on with EPSTEIN, she felt like an outcast.
did not feel part of the circle that included EPSTEIN, MAXWELL,
, and another girl thought was close to
3501.054-008
Page 2 of 6
CONFIDENTIAL
EFTA_00058008
EFTA01245689
FD-302a (Rev. 54-10)
50D—NY-3027571
Continuation of FD-302 (U) Interview of on 11.21.19 ‘O, 11/21/2019 ,page 3 of 6
in age. was very much in the "inner circle". was not
sure if it was this trip in which she met . EPSTEIN suggested a photo
shoot. took the photographs. remembered she was in a bathing
suit but may not have had her clothes on. was not sure if this was
before she had turned 18 years old.
When came back from, they flew her to Florida and the
island. thought this could have been around April/May2003.
EPSTEIN and MAXWELL seemed like they had a business partnership. MAXWELL
was very cold. did not feel comfortable around MAXWELL. MAXWELL made
no effort to be friend. The time where MAXWELL went horseback
riding with was the nicest she ever was to her and was just more
inquisitive with
and others did not talk openly about everything. It was all very
secretive. MAXWELL was especially secretive. MAXWELL would be around doing
things on her computer. Even as time passed, things stayed that way, in
terms of no one talking openly.
In or around the end of 2004/beginning of 2005, EPSTEIN sent back
to
recalled a girl named . EPSTEIN had massage him
on the island. was told a specific time to go into the room.
went into EPSTIEN's room and was there. was older than
Before had turned 18 years old, she was told by someone to give
EPSTEIN a massage.
Before left New Mexico, she had been preparing to
gave up her apartment and gave notice to her job. remembered
going to the island after traveled with EPSTEIN and
others for some time. EPSTEIN encouraged to
. EPSTEIN flew to
3501.054-008
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CominuationofFD-30201 (U) Interview of on 11.21.19 JD, 11/21/2019 _ haw 4 of 6
would be gone for months at a time.
recalled some of the people who gave EPSTEIN massages. There were
a few women who were older than including one woman named and
another , who had a tattoo. recalled a younger lady named
(known to law enforcement as ). saw a few
times in the kitchen. thought was around her age; was
approximately 18/19 years old at the time. thought MAXWELL and/or
scheduled the massages because they scheduled everything. Both
MAXWELL and told to give EPSTEIN massages at a certain time.
did not know if they told her this before she turned 18 years old.
Before turned 18 years old, she went to EPSTEIN's house in New
York. was there for maybe a few hours before flying with EPSTEIN on
his private plane. did meet LESELY in person at the office.
thought she may have been over 18 when she met LESLEY.
Someone did ask for pass ort to hold it. recalled
specifically it was on a trip from thought may have
asked for it, but said she would be guessing it was
The first assault in New York was before turned 18 and took place
at EPSTEIN's home. recalled that there was an office to the left when
she walked in. This is where waited. JOJO and his wife, who were
employed by EPSTEIN, were there. JOJO took and told her she could go
to the dining room, which is where the assault occurred. EPSTEIN entered
the room; they conversed for a bit, then EPSTEIN put his hands down
pants and commented on how wet she was.
In New Mexico, invited into the room to participate.
remembered there being an indoor swimming pool on the ranch and to the left
was a massage room. and were still in their swimsuits and
EPSTEIN wanted a massage. EPSTEIN was naked, face down on the massage
table. and both started massaging him. EPSTEIN fondled and
touched , touching her vagina and breasts while he "jerked off".
EPSTEIN grabbed and stuck his hand in her vagina. froze when
this happened. EPSTEIN asked to touch his nipples; was frozen.
EPSTEIN ejaculated and then it was over. acted like it was something
that was normal; did not freeze when this happened. did not
3501.054-008
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Continuation of F0.302 of (U) Interview of on 11.21.19 , o, 11/21/2019 page 5 of 6
think that touched her. They did not get consent to do
this. EPSTEIN removed suit top. cried and EPSTEIN
continued. tried not to show that she had tears falling.
During the assault in New York, was frozen. She did not recall if
she froze.
In Florida, EPSTEIN climbed into bed and raped her.
described this as nonconsensual vaginal penetration by EPSTEIN's penis. The
same thing happened in Paris.
In the Virgin Islands, EPSTEIN had touch his genitals. There was
no penetration involved on the island.
recalled in Paris meeting HARVEY WEINSTEIN. WEINSTEIN grabbed her
arm and told her to go get BONNIE LNU or and they will take their
shirts off for him.
turned 18 years old celebrated her birthday with
EPSTEIN and others. EPSTEIN gave and antique gifts, giving
a necklace. could not remember any further details around
this. This happened before was sent away.
recalled a time in Florida where she wore overalls and asked if she
looked ok. EPSTEIN told her, "Yea, for a homeless person".
EPSTEIN did not like black people. EPSTEIN told this in general
conversation.
MAXWELL called all the time; thought MAXWELL called
her this because
When all of them were shopping together, including EPSTEIN, MAXWELL,
, and , and EPSTEIN was picking things out for her, this was
after had turned 18.
asked EPSTEIN why he chose her to help and he told her it was
because she was inquisitive and he could tell how smart she was for how old
she was. thought this was sad because it was such a lie.
was asked how she would feel if charges were brought against
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MAXWELL and thought it was the right thing to do. Learning
about involvement and how she did not do anything when she was
present effected view on the possibility of being charged
with a crime. felt though that if were a victim of EPSTEIN,
could find compassion, but understanding was that was
very involved.
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3 pages
DRAFT 1
Tina
Editor
Daily Beast
New York, NY
Re Jeffrey Epstein
Dear Ms.
This letter is written for the purpose of requesting that you review both the
accuracy of a series of past articles originating with the Dail Beast, each
authored by one of the Daily Beast's contributing writers,
and the appropriateness of the Daily Beast disseminating any further articles
about Mr. Epstein — a very real likelihood, given an email sent to our client
by the writer, absent your intervention. We ask you to conduct this review
for the purpose of determining (a) whether the facts as stated in the prior
(and the prospective future) articles are accurate and (b) whether the
intensity of multiple repetitive articles is appropriate.
Mr. Epstein, as you may know, has completed his state sentence for events
that occurred over five years ago. There have been no allegations of any
improper conduct since the fall of 2005. Mr Epstein, instead, has returned to
his life as a philanthropist and financial advisor. The series of three articles
published on July 21, July 22, and July 29, 2010 have already done
significant damage to Mr. Epstein. Given that they contain provably
untruthful inaccuracies and omissions of material fact, we are asking you to
defer any future articles authored by Ms. until such a time as you
can review the articles, and, if possible, meet with us to discuss the subject
matter.
EFTA00727881
Without in anyway providing each inaccuracy, just several examples
should illustrate the seriousness with which we view the issue, and our
request for your intervention:
1. One of the two principal sources for Ms articles is a former
Miami bookeeper for the moSaialv1C2, see eg 7-22-10 article,
bulletpoint 5. Her name is . She plead guilty to grand
theft in the first degree in the 11th Judicial Circuit Court for Dade County,
Florida, on December 3, 2007 and was sentenced to 1 year of community
control and 19 years of probation as a result of her embezzling $148,000
from the modeling agencies for which she was employed (Case No F07-
10933). She was also charged with Organized Fraud — Scheme to Defraud.
She is an untrustworthy biased source of information. The information
regarding her criminal charge and conviction and its direct relationship to
her motive to give false testimony was available to your reporter but omitted
from her articles;
2. Mr. Epstein did not, as your articles claim, see eg 7-22-10 bullet point 4,
give Mr Brunel $1,000,000 to start his modeling agency;
3. Despite both a state and federal investigation, Mr. Epstein has never been
charged — and never participated — in wrongful conduct, particularly
molesting three 12 year olds as alleged by Ms. in her articles, see eg
7-21-10 nor has this allegation been made in prior civil cases as alleged by
Ms.
4. No civil plaintiff has ever been on Mr. Epstein's planes or named in his
flight logs, com are to Ms allegations on 7-22-10;
5. was not 14 when she came to the United States and is
not 24 at the time of Ms. 7-21-10 article;
6. Ms. , who is quoted by Ms. in her 7-21-10 article as
saying that Mr. Epstein told her the "younger the better" also told the Palm
Beach police in the very same tape recorded interview that Mr.thtsaid
"he likes the girls that are between the ages of like 18 and 20"
Taped Interview, pg. 12);
8. Mr. Epstein never "committed" nor even considered (much less agreed) to
a 10 year federal sentence com are to Ms 7-21-10 contention) a
claim attributed to Ms second source plaintiff's attorney
Edwards;
9. Ms. la deliberately omitted the important fact that attorney Edwards
is being sued by Mr. Epstein for wrongdoing related to his partnership with
Scott Rothstein, just as she omitted any context for the allegations attributed
to the prior bookkeeper see par 1 supra;
EFTA00727882
10. 7 plaintiffs did not each receive $1,000,000 during the week of July 14,
2010 as claimed by Ms see 7-22-10;
11. Mr. Epstein has not been accused of "sex trafficking", nor has he
committed "sex trafficking" nor is he, to the knowledge of any of his
attorneys, being investigated for "sex trafficking" despite Ms.
repeated allegations to the contrary, see articles of 7-21-10 bullet point 4 and
7-29-10. Given Ms concession in her 7-29-10 article that federal
sources declined to comment on such an incendiary allegation we would
question whether there exists a trustworthy source for this claim;
12. Dr. Stephen Alexander's telephone has not been disconnected with no
forwarding number as claimed by Ms. in her July 29, 2010 article
We request that you conduct an independent review of the integrity of the
three prior articles and delay disseminating a fourth until after the review.
We remain available to meet with you
YT
EFTA00727883
DataSet-9
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2 pages
LESLEY GROFF
Cell Phone: E-Mail:
PROFILE:
Seasoned, Polished Executive/Personal Assistant with dedicated longevity of 10 years plus to a Manhattan Billionaire Fund
Manager/Socialite with excellent communication skills and a professional demeanor.
OBJECTIVE:
To obtain an Executive/Personal Assistant position to support high profile, fast paced "C" Level Executive.
PROFESSIONAL EXPERIENCE:
Executive/Personal Assistant to Manhattan Billionaire Fund Manager/Socialite
Feb.2001-Present New York, New York
• Manage all day to-day affairs, which include heavy calendaring with Outlook management, scheduling,
conference calls, coordinate complex domestic and international travel via private and commercial
aviation, transportation and accommodations.
• Act as gatekeeper, screen, route and handle all telephone calls, emails, and texts, heavy interaction with
high level associates, financiers, government officials, royalty, socialites, models, actors, Pulitzer prize
winners, Presidential candidates, former Prime Ministers, Members of Parliament, Scientists, Academics
from around the world- capable of using discretion and conducting myself in a highly professional
manner.
• Manage employers 10 guest apartments, coordinating travel of guests, scheduling maids, food, up keep
of maintenance, cable and Internet services.
• Supervise and coordinate all household staff, engineer, drivers, pilots, bodyguard, trainer, controller,
contractors and interior decorators at all households: Manhattan, Palm Beach, Santa Fe, Paris and a
private island in the Caribbean. Liaison between accountants, attorneys, traders. Assist and provide
support to in-house attorney.
• Anticipate, plan, follow-up and organize breakfast and lunch meetings, dinner parties, cocktail hours and
afternoon teas.
• Maintain confidential office and personal files, prepare and write correspondence; thank you notes; order
office supplies; database management; run personal errands; buy gifts; expense reports, Blackberry
savvy, conduct internet research, track flight logs, bid at Sotheby's and Christie's.
• Ability to source vast network of PA's and contacts to locate the best of everything.
Village Office Supply-Owner
May1990-Feb. 2001 Bridgewater, NJ
• Facilitated the growth of a commercial office supply company from its infancy to over $24 million,
functioning in every capacity required to develop a new business.
• Managed and nurtured over 3,000 accounts. Directly served as primary account representative to 40 key
accounts.
• Recruited, hired, trained and supervised 25 customer service and sales reps, responsible for their
performance and evaluations
• Marketed our service and sold over one million different office, janitorial and stationary supplies to
existing and prospective clients.
• Resolved customer complaints with professionalism and a positive attitude.
EDUCATION:
University of Texas at Dallas 1990 BA of Liberal Arts
University of London- Summer 1987 British Art History
SKILLS: Microsoft Word, Outlook
INTERESTS: Fitness, Travel, Family
EFTA00305695
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2 pages
ATTERBURY GOLDBERGER WEISS.
JOSEPH R.ATTERBURY
• t JACK A. GOLDBERGER
• JASON S.WELSS
-Board Certlied Criminal Tide Attorney
Member o1 New Jersey & Florida Bars
December 3, 2009
Barbara Burns, Esquire
State Attorney's Office
401 North Dixie Highway
West Palm Beach, Florida 33401
RE: State of Florida v. Jeffrey Epstein
Case No. 2008CF009381A
Dear Barbara,
Pursuant to our telephone conversation of November 30, 2009 and your subsequent email
to me, I am providing the following information to you concerning Jeffrey Epstein's air travel
from May 1, 2009 through November 30, 2009.
As you know, Mr. Epstein was in the custody of the Palm Beach County Sheriffs Office
until July 22, 2009. I have confirmed that since Mr. Epstein's release from custody, he has
traveled twice by air. The first trip was on September 14, 2009 when he traveled by
helicopter to Miami to meet with counsel. He returned that day from Miami to Palm Beach
County by automobile. Larry Visoski was the pilot and Was the only
other passenger. Both the trip and the mode of transportation were pre-approved by
probation. On August 27, 2009 Mr. Epstein flew on a single engine Cessna aircraft to
Sikorsky Helicopters in northern Palm Beach County. Larry Visoski and-
accompanied Mr. Epstein on this short flight. Once again the trip and the method of
transportation were pre-approved by probation. There have been no other aircraft flights
taken by Mr. Epstein during the time period. I am told there are not flight logs kept for the
helicopter but I am enclosing the fuel receipt for the Miami helicopter trip as well as another
document confirming the September 14, 2009 Palm Beach - Miami helicopter flight. I am
also enclosing documents for the August 27, 2009 Cessna flight to Sikorsky Helicopters.
On another note, there appears to be false information being presented to either the State
Attorney's Office or the Probation Office about Mr. Epstein allegedly violating the terms of
his probation. None of this is true and in fact Mr. Epstein has an unblemished record with
probation without any violations since his being placed on supervision. I note that many
of the false allegations against Mr. Epstein have been brought by the Scott Rothstein law
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firm which has since filed bankruptcy as a result of massive fraud by one of its partners.
It is alleged that they used their civil cases filed against Mr. Epstein as one of their more
lucrative devices to perpetrate this fraud. Based on what I have learned and read, there
have been false filings, forged judge's signatures, and forged Eleventh Circuit Opinions.
It is also possible that other third parties have engaged in this conduct by falsely alleging
Mr. Epstein has violated the terms of his probation.
With this in mind, It appears that Mr. Epstein could be a victim of fabricated attacks
designed to do nothing more than question his compliance with his probation and
community control requirements. I truly want my client, as I am sure you do, to complete
his probation without continued false accusations being made against him. I would
suggest a meeting so we may discuss these problems. Given the fact that false
accusations are being made against my client, I would take the unusual step of producing
my client for such a meeting if you think it would be helpful.
Please give me a call with your thoughts on this and whether those documents satisfy your
request.
trulyyours
Jjtk A. Goldberger
JAG/slm
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From: GMAX
Sent: Wednesday, June 8, 2011 1:42 PM
To: Jep
Subject: FW: Vanity Fair
we stick to written responses rather than engage via 'phone. Klein has form for story-twisting re Hillary Clinton. Written
responses at least give us an audit trail of what was said.
A lot of this is Mail on Sunday rehash. Klein has our statement, but is offering the chance for further clarification...I get
the feeling he's likely to make unflattering assumptions if we don't give him on the record answers.
Please advise on those questions which you feel you more comfortable answering. We can head him off at the pass on
those and put legal frighteners on him elsewhere.
Just a caveat - we should be aware that there is a chance that anything other than fully robust answers might be
construed as inadvertent admissions of wrongdoing, so we will need legal team to advise on precise wording. Do you
want me to pass this on to Devonshires if you have not already done so...?
best
Ross
Dear Ross,
Here are some fact-checking questions for Ghislaine Maxwell to comment on and answer:
1. Do Jeffrey Epstein and Ghislaine Maxwell share a home in London or anywhere else? Do they still see each other?
Does Epstein help support Ghislaine? Her friends tell me that Ghislaine once loved Epstein. Does she still love him?
MS MAXWELL DOES NO SHARE ANY HOMES WITH MR EPSTEIN. MR EPSTEIN DOES NOT SUP=ORT MS MAXWELL IN
ANYWAY. MS MAXWELL HAD INFACT BEEN IN COMMITTED RELATIONS=IP WITH SOMEONE ELSE FOR THE PAST 7 YEARS
2. The Mail on Sunday published a photograph showing the Duke of York with his arm around Standing
off to one side in the=BR> photo was Ghislaine Maxwell. The newspaper said that this photo taken in Ghislaine's London
home. Was it? Did Jeffrey Epstein take the photo? If not, who did?
MS MAXWELL HAS NO RECOLECTION OF THE PHOTO BEING EVEN TAKEN GIVEN WE ARE TA=KING AN EVENT THAT
ALLEDGEDLY TOOK PLACE OVER 10 YEARS AGO IT WOULD BE SURP=ISING
3. According to Ghislaine Maxwell recruited her as Epstein's "sex slave" when she was 15 years old and
arran=ed for her to see Andrew three times—at Jeffrey Epstein's homes in London =nd New York and on his private
Caribbean island, Little Saint James—where, said, she'd been "sexually exploited by Epstein'= adult male peers,
including royalty." Would Ghislaine please comment on this assertion by
MS MAXWELL MET MS WHEN SHE WAS 17 AND WAS HIRED AS A MASSUSE.=MS WAS LIVING AT THE
TIME WITH HER FIANCE. MS HAS A PRIOR S=XUAL HASSARASSMENT SUIT AGAINST OTHER INDIVIDUALS THAT
WAS THROWN OUT FOR L=CK OF HER CREDABILITY AND DRUG USE. MS FINALLY FLED THE US TO
AVOID=ARREST FOR THEFT. I THINK GIVEN THIS AND OTHER HIGHLY INDICATIVE EVENTS IN =ER LIFE IT IS IMPOSSIBLE TO
EFTA_R1_01688278
EFTA02539710
BELIEVE ONE WORD OUT OF HER MOUTH. FURTHER THE =NCENTIVE OF A LARGE AMOUNT OF MONEY PAID BY A
NEWSPAPER NO DOUBT ADDED TO H=R COLOURFUL 'MEMORIES' WHICH IN FACT ARE NOTHING BUT MADE UP ST=RIES.
4. The Mail on Sunday and other newspapers ran the story about Andrew's rendezvous with in Ghislaine
Maxwell'= London home. These reports said that Jeffrey Epstein and Ghislaine Maxwell left the Duke of York and
alone for several hours, and that the next morning Ghislaine Maxwell told that the Duke had a
good time. Would Ghislaine please comment on this story. What did the Duke tell Ghislaine about his rendezvous with
5. The Mail on Sunday said it had evidence to support story—flight logs from Jeffrey Epstein's
Boeing=727 and Gulfstream jet. Was Ghislaine Maxwell on these airplanes and who else was onboard?
AGAIN TO REMEMBER ANY SPECIFIC FLIGHT AND WHO WAS ON BOARD A PLANE FOR EVEN=S THAT ALEDEGEDLY TOOK
PLACE OVER 10 YEARS AGO IS SIMPLY UNREALISITC
6. According to a sworn deposition by Juan Alessi, a former employee at Jeffrey Epstein's Palm Beach estate, Prince
Andrew attended nakedc=R> pool parties and was treated to massages by a harem of adolescent girls.
MS MAXWELL CANNOT COMMENT ON WHAT MR ALESSI ALLEDEGDLY SAW OR DID NOT SEE B=T MS MAXWELL NEVER
SAW THE DUKE IN ANY STATE OF UNDRESS AND HE WAS INDEED A=WAYS PROPERLY ATTIRED.
That's it for now.
I hope that you can arrange for me to speak directly to Ghislaine.
All the best,
Ed
Edward Klein
Ross Gow
Managing Partner
ACUITY Reputation
www.acuityreputation.com
End of Forwarded Message
2
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TONJA HADDAD PA
September 26. 2013
Via Electronic Mail
Jack Scarola, Esq.
Searcy Denney et al.
Re: Epstein v. Edwards et ed.
Mr. Scarola:
As discussed, the items listed below (numbered as they appear on your exhibit list) were
never provided to us during discovery in this matter. Please advise if you agree that you
will not use this substantial (and irrelevant) list of items, or if we need to address it in
our Motion in Limine. Back on April 23, 2013, you were served with the following
request as listed on Schedule A to Brad's deposition notice:
12. Copies of any and all documents you intend to introduce at trial in support of the
allegations made by you in your Fourth Amended Counterclaim you filed in this matter.
At the hearing on your Motion for Protective Order on June 10, 2013, you told the judge
specifically that you were providing all items responsive to that request.
7 The last one is copies of any and all
8 documents you intend to introduce at trial in
9 support of the allegations made by you in the
to fourth amended counterclaim. Again, we are
11 giving them all the evidence that we intend to
12 rely upon.
See Transcript ofJune 10. 2013 hearing, p. 27, which is attached to this letter.
4. Video of Jeffrey Epstein's home and route from victim to Epstein's home
9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez
II. Jeffrey Epstein phone records
12.
1
phone records
EFTA01099380
15. All probable cause affidavits related to criminal investigation of Jeffrey Epstein
16. All evidence, information and documents taken or possessed by FBI related to
criminal investigation of Jeffrey Epstein
17. Victims' statements to the FBI related to criminal investigation of Jeffrey
Epstein
18. Video of Search Warrant of Jeffrey Epstein's home being executed
19. Application for Search Warrant of Jeffrey Epstein's home
27. Yearbooks of Jane Doe
28. 2002 Royal Palm Beach High School Year Book
29. 2001 Royal Palm Beach High School Year Book
30. 2003 Palm Beach Gardens High School Year Book
31. Affidavit and Application for Search Warrant on Jeffrey Epstein's home
32. Tape recording or transcript of recording of conversation between Jeffrey
Epstein and George Rush
33. Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his
home during criminal investigation
39. All statements made by Jeffrey Epstein
40. List of properties and vehicles in Larry Visoski's name
50. Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes
52. Probable Cause Affidavits prepared against Jeffrey Epstein and
53. Audio tape of
Epstein's
54. Photographs, videos and books taken in the search warrant of Jeffrey
home
to law
55. Documents related to or evidencing Jeffrey Epstein's donations
enforcement
EFTA01099381
56. Victim Notification Letter from US Attorney's Office to Victim
57. Expert Dr. L. Dennison Reed's Report of Victim
59. All reports and documentation generated by Palm Beach Police Department
related to Jeffrey Epstein
60. All Witness Statements generated by Palm Beach Police Department relating to
Jeffrey Epstein
61. Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs
62. Passenger lists for flights taken by Jeffrey Epstein
63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island project
65. MC2 emails involving communications of Jeffrey Epstein, Jeff Puller,
Pappas Suat, Jean Luc Brunel and Amanda Grant
68. Massage Table
69. Lotions taken from Jeffrey Epstein's home during search warrant
70. Computers taken from Jeffrey Epstein's home during search warrant
71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during
search warrant
77. CAD calls to 358 El Brillo Way, Palm Beach FL 33480
80. Letter from Chief' to
82. Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
83. Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
84. Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
85. Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
86. Letter from Guy Fronstin to Assistant State Attorney dated 410-06
87. Letter from Goldberger dated 6-22-06
EFTA01099382
88. All subpoenas issued to State Grand Jury
89. Documents related to the rental of a vehicle for
90. Ted's Sheds Documents
91. Documents related to property searches of Jeffrey Epstein's properties
92. Arrest Warrant of
93. Police report regarding icking up money dated 11-28-04
94. List of Trilateral Commission Members of 2003
96. Guy Fronstin letter dated 4-17-06
100. Victim's GED testing information and results
101. JEGE, Inc. Passenger Manifest
102. Hyperion Air Passenger Manifest
103. Flight information for
104. Passenger List Palm Beach flights 2005
105. Jeffrey Epstein notepad notes
108. letter to dated 5-1-06
110. Police Report dated 11-28-04
Ill. Compulsory Medial Examination of victim, CMA
112. Victim's school records and transcripts
113. Victim Notification letter dated 7-9-08
114. Victim's employment records from IHOP
115. Police report of Juan Alessi theft at Jeffrey Epstein's home
116. Victim's Medical Records from Milton Girls Juvenile Facility
117. Victim's Medical Records from Dr. Randee Speciale
EFTA01099383
118. Victim's Medical Records from Wellington Regional Hospital
119. Victim's Medical Records from St. Mary's Medical Center
120. Victim's Medical Records from United Health
121. All surveillance conducted by law enforcement on Jeffrey Epstein's home
122. Emails received from Palm Beach Records related to Jeffrey Epstein
123. All items listed on the Palm Beach Police Property Report Lists
124. All items taken in the execution of the search warrant of Jeffrey Epstein's home:
358 El Brillo Way, Palm Beach FL 33480
127. All documents produced by Palm Beach Police Department prior to the
deposition of Detective Recarey
128. Photographs of all persons listed on Victims' Witness Lists
129. Statements, deposition transcripts, videotaped depositions and transcripts taken
in connection with this and all related cases and exhibits thereto
130. Any and all expert witness reports and/or records generated in preparation for
this litigation by any party to this cause
132. Curriculum vitae of Dr. Ryan Hall
133. Any articles or publications of Dr. Ryan Hall
134. Any articles or publications of Dr. Richard Hall
135. Any articles or publications of Dr. L. Dennison Reed
136. All items and documentation review by Dr. L. Dennison Reed
137. Transcript and video (DVD) of IME of Victims
138. All exhibits to Dr. L. Demlison Reed's Deposition
139. All exhibits to Dr. Richard Hall's Deposition
140. All items and documents reviewed by Dr. Richard Hall
141. All items and documents reviewed by Dr. Ryan Hall
EFTA01099384
142. Demonstrative aids and exhibits including, but not limited to, anatomical charts,
diagrams and models, surveys, photographs and similar material including blow-ups of
the foresaid items.-
143. Any and all mortality tables
By notifying you of this defect pursuant to our requirement that we try to resolve
discovery issues before we bring them before the court, we are in no way agreeing to
their validity, relevancy, or admissibility in any way. We are further not waiving the
right to assert any and all objections to these items as permitted by law.
Sincerely,
TONJA HADDAD, II
Tonja Haddad Coleman
for the firm
cc: Parties on Service List
EFTA01099385
27
1 I skipped over number 9, copies of any
2 and all receipts, reports, invoices or other
3 documents evidencing treatment for your mental
4 anguish, embarrassment, anxiety, as alleged in
5 your counterclaim, there has been no formal
6 treatment, we have already told them none.
7 The last one is copies of any and all
documents you intend to introduce at trial in
9 support of the allegations made by you in the
10 fourth amended counterclaim. Again, we are
11 giving them all the evidence that we intend to
12 rely upon.
13 So the motion for protective order is
14 directed principally to number 1, number 2,
15 number 3, number 4, as it relates to anything
16 other than attorney's fees awards for Bradley
17 Edwards, and number 5 and the partnership
18 agreement in number 6.
19 So, understanding what we are claiming
20 and the fact that they are entitled to test
21 our claim, the answer to the question Your
22 Honor asks is, yes, they are entitled to test
23 our claim that this is the amount of time that
24 Brad Edwards devoted to the defense of this
25 case, but they haven't asked for anything that
WWW.USLEGALSUPPORT.COM
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IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT,
INAND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA0408003OOOCMBAG
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE: DAVID CROW
VS.
SCOTT ROTHSTEIN,
individually, BRADLEY J.
EDWARDS, individually,
Defendants/Counter-Plaintiff,
EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury
Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of
Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits (numbered in order as they
appeared in Edwards's Revised Exhibit List):
I. All applicable criminal statutes
4. Video of Jeffrey Epstein's home and route from victim to Epstein's home
5. Order confirmation from Amazon.com for purchase of books "SM 101: A
Realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude-Principles, Skills and
Tools" and "Training Miss Abernathy: A Workbook for Erotic Slaves and Their Owners"
6. Non-Prosecution Agreement
7. Jane Doe 102 Complaint
EFTA01113966
8. Messages taken from message pads found at Epstein's home
9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez
10. Jeffrey Epstein flight logs
I I. Jeffrey Epstein phone records
12. phone records
13. Jail Visitation Logs
14. Jeffrey Epstein's probation file
15. All probable cause affidavits related to criminal investigation of Jeffrey Epstein
16. All evidence, information and documents taken or possessed by FBI related to
criminal investigation of Jeffrey Epstein
17. Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein
18. Video of Search Warrant of Jeffrey Epstein's home being executed
19. Application for Search Warrant of Jeffrey Epstein's home
20. Complain v. Epstein and all subsequent Amended Complaints
21. All records of homes, properties, bank accounts and any and all records related to
Jeffrey Epstein's assets
24. List of corporations owned by Jeffrey Epstein
25. All documents evidencing relationship between Jeffrey Epstein and Jean Luc
Brunel
26. All documents evidencing relationship between Jeffrey Epstein and MC2 or any
modeling agencies
27. Yearbooks of Jane Doe
28. 2002 Royal Palm Beach High School Year Book
29. 2001 Royal Palm Beach High School Year Book
30. 2003 Palm Beach Gardens High School Year Book
EFTA01113967
31. Affidavit and Application for Search Warrant on Jeffrey Epstein's home
32. Tape recording or transcript of recording of conversation between Jeffrey Epstein
and George Rush
33. Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his
home during criminal investigation
34. The Palm Beach State Attorney's Criminal file against Jeffrey Epstein
35. All documents related to Jeffrey Epstein's 6/30/08 conviction
36. Jeffrey Epstein's criminal plea colloquy
37. Public records from the Department of Corrections related to Jeffrey Epstein
38. Records from the Florida Department of Law Enforcement related to Jeffrey
Epstein
39. All statements made by Jeffrey Epstein
40. List of properties and vehicles in Larry Visoski's name
41. All of Jeffrey Epstein's Responses to Requests for Production, Requests for
Admission, Answers to Intelmgatories in 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
42. All discovery related responses of Jeffrey Epstein in 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
43. Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him
44. All Complaints in which Jeffrey Epstein was a plaintiff or defendant
45. Jeffrey Epstein's Deposition testimony and discovery responses in 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
46. Jeffrey Epstein's Deposition testimony and discovery responses in State Court
cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXMB AB and E.W. v.
Jeffrey Epstein, Case No. 502008CP003626XXXXMB
EFTA01113968
48. Any and all newspaper articles, online articles or publications related to Jeffrey
Epstein
49. Report and Analysis of Jeffrey Epstein's assets
50. Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes
52. Probable Cause Affidavits prepared against Jeffrey Epstein anc
53. Audio tape of
54. Photographs, videos and books taken in the search warrant of Jeffrey Epstein's
home
55. Documents related to or evidencing Jeffrey Epstein's donations to law
enforcement
56. Victim Notification Letter from US Attorney's Office to Victim
57. Expert Dr. L. Dennison Reed's Report of Victim
58. Palm Beach Police Department Incident Report dated 4/20/06
59. All reports and documentation generated by Palm Beach Police Department
related to Jeffrey Epstein
60. All Witness Statements generated by Palm Beach Police Department relating to
Jeffrey Epstein
61. Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs
62. Passenger lists for flights taken by Jeffrey Epstein
63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island project
64. Jeffrey Epstein's bank statements
Jeffrey Epstein's tax returns (this item not numbered on Edwards's Trial Exhibit
Listt)
' • ' • ein, Jeff Puller
EFTA01113969
66. DVD of plea and colloquy taken on 6-30-08
67. Transcript of plea and colloquy taken on 6-30-08
68. Massage Table
69. Lotions taken from Jeffrey Epstein's home during search warrant
70. Computers taken from Jeffrey Epstein's home during search warrant
71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during
search warrant
72. No Contact Orders entered against Jeffrey Epstein
73. Criminal Score Sheet regarding Jeffrey Epstein
74. Documents evidencing Jeffrey Epstein's Community Control and Probation
75. Jeffrey Epstein's Sex Offender Registration
76. Jeffrey Epstein's Booking photograph
77. CAD calls to 358 El Brillo Way, Palm Beach FL 33480
78. List of Jeffrey Epstein's House contacts
79. Documents related to Jeffrey Epstein's investments
80. Letter from Chief Michael Reiter to Barry Krischler
81. List of planes owned by Jeffrey Epstein
82. Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
83. Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
84. Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
85. Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
86. Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
87. Letter from Goldberger dated 6-22-06
EFTA01113970
88. All subpoenas issued to State Grand Jury
89. Documents related to the rental of a vehicle fa
90. Ted's Sheds Documents
91. Documents related to property searches of Jeffrey Epstein's properties
92. Arrest Warrant
93. Police report regardin picking up money dated 11-28-04
94. List of Trilateral Commission Members of 2003
95. Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
96. Guy Fronstin letter dated 4-17-06
97. Jeffrey Epstein Account Information
98. Jeffrey Epstein Criminal Closeout Sheet-
99. Jeffrey Epstein Polygraph Test and Results
100. Victim% GED testing information and results
101. JEGE, Inc. Passenger Manifest
102. Hyperion Air Passenger Manifest
103. Flight information fa
104. Passenger List Palm Beach flights 2005
105. Jeffrey Epstein notepad notes
106. Pleadings of _1 and 2 v. US case
107. Jeffrey Epstein 5th Amendment Speech
108. Reiter letter to Krisher dated 5-1-06
109. Jail receipts of Jeffrey Epstein
110. 'olice Report dated 11-28-04
EFTA01113971
11. Compulsory Medial Examination of victim, CMA
112. Victim's school records and transcripts
113. Victim Notification letter dated 7-9-08
114. Victim's employment records from IHOP
115. Police report of Juan Alessi theft at Jeffrey Epstein's home
116. Victim's Medical Records from Milton Girls Juvenile Facility
117. Victim's Medical Records from Dr. Randee Speciale
118. Victim's Medical Records from Wellington Regional Hospital
119. Victim's Medical Records from St. Mary's Medical Center
120. Victim's Medical Records from United Health
121. All surveillance conducted by law enforcement on Jeffrey Epstein's home
122. Emails received from Palm Beach Records related to Jeffrey Epstein
123. All items listed on the Palm Beach Police Property Report Lists
124. All items taken in the execution of the search warrant of Jeffrey Epstein's home:
358 El Brillo Way, Palm Beach FL 33480
125. All copies of convictions related to Jeffrey Epstein
126. Jeffrey Epstein criminal records
127. All documents produced by Palm Beach Police Department prior to the deposition
of Detective Recarey
128. Photographs of all persons listed on Victims' Witness Lists
129. Statements, deposition transcripts, videotaped depositions and transcripts taken in
connection with this and all related cases and exhibits thereto
130. Any and all expert witness reports and/or records generated in preparation for this
litigation by any party to this cause
132. Curriculum vitae of Dr. Ryan Hall
EFTA01113972
133. Any articles or publications of Dr. Ryan Hall
134. Any articles or publications of Dr. Richard Hall
135. Any articles or publications of Dr. L. Dennison Reed
136. All items and documentation review by Dr. L. Dennison Reed
137. Transcript and video (DVD) of IME of Victims
138. All exhibits to Dr. L. Demlison Reed's Deposition
139. All exhibits to Dr. Richard Hall's Deposition
140. All items and documents reviewed by Dr. Richard Hall
141. All items and documents reviewed by Dr. Ryan Hall
142. Demonstrative aids and exhibits including, but not limited to, anatomical charts,
diagrams and models, surveys, photographs and similar material including blow-ups of
the foresaid items.- need to see before we agree
143. Any and all mortality tables
149. All pleadings and attachments in the action under the Crime Victims Rights Act
prosecuted by Bradley Edwards on behalf of victims of Epstein's criminal molestations.
150. All attachments to Edwards's Motion for Summary Judgment.
151. All time records and hourly billing documentation produced in discovery.
152. All pleadings filed by Epstein in the Rothstein bankruptcy proceeding.
153. All Settlement Agreements between Epstein and victims of his sexual
molestations.
Epstein objects to all of the afore-referenced Exhibits on several grounds,
including, but not limited to: Relevance; Prejudice; Confusion; Misleading; Hearsay;
Impermissible/Inadmissible Character Evidence; Impermissible/Inadmissible Evidence of
other Crimes, Wrongs, or Acts; and the fact that most of the items on this list were not
EFTA01113973
provided to Epstein through discovery or otherwise in this case, in direct violation of this
Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, and
Epstein's "Exhibit A" to Bradley J. Edwards's Deposition Duces Tecum.
By listing these grounds for objection to the afore-listed Exhibits, Epstein is not
waiving his right to assert additional objections, or objections to any non-listed Exhibits
at trial.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served,
via electronic service, to all parties on the attached service list, this September 19, 2013.
/s/ Tonja Haddad Coleman
Tonja Haddad Coleman, Esq.
Florida Bar No.: 176737
Tonja Haddad, PA
5315 SE 7th Street
Suite 301
Fort Lauderdale, Florida 33301
954.467.1223
954.337.3716 (facsimile)
Attorneys for Epstein
EFTA01113974
SERVICE LIST
CASE NO. 502009CA040800XXXXMBAG
Jack Scarola, Esq.
[email protected]; [email protected]
Searcy Denney Scarola et al.
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
Jack Goldberger, Esq.
[email protected]; [email protected]
Atterbury, Goldberger, & Weiss, PA
250 Australian Ave. South
Suite 1400
West Palm Beach, FL 33401
Marc Nurik, Esq.
I East Broward Blvd.
Suite 700
Fort Lauderdale, FL 33301
Bradley J. Edwards, Esq.
[email protected]
Fanner Jaffe Weissing Edwards Fistos Lehrman
425 N Andrews Avenue
Suite 2
Fort Lauderdale, Florida 33301
Fred Haddad, Esq.
[email protected]
1 Financial Plaza
Suite 2612
Fort Lauderdale, FL 33301
Tonja Haddad Coleman, Esquire
[email protected]; [email protected]
Law Offices of Tonja Haddad, P.A.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301
Attorneys for Jeffrey Epstein
EFTA01113975
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2 pages
From: Lesley Groff wrote:
> Lesley:
> Sorry I did not get back to you sooner - seems that I do have all the pages. I think the
numbering at the top was off somehow.
> Thank you for resending.
•
> Mary Ellen
> US Treasury Department Circular 230 requires that we inform you that any federal tax advice
contained in this communication (including attachments) is not intended or written to be
used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii)
promoting, marketing or recommending to another party any transactions or matter addressed
herein.
> --- On Wed, 5/25/11, Lesley Groff < > wrote:
>> From: Lesley Groff
>> Subject: Re:
>> To: "George Delson" < >
>> Date: Wednesday, May 25, 2011, 7:32 PM
>> very strange on the phone line...I am
>> receiving calls so not sure what is wrong. I will re
» fax you the entire package. the flight logs start with
>> April 23rd and go to May 22
>>
>> Let me know you receive them all. thanks!
>> On May 25, 2011, at 3:25 PM, George Delson wrote:
>>
>>>
>» Lesley:
>>>
>>> I was missing some pages from the fax before.
>> Page 1, 3, 6, and 10. Also when I call you on 9895 it
>> seems to bounce back here.
>>>
>>> Thanks.
>>>
>>> Mary Ellen
>>>
>>>
>>> US Treasury Department Circular 230 requires that we
>> inform you that any federal tax advice contained in this
>> communication (including attachments) is not intended or
>> written to be used, for the purpose of (i) avoiding
>> penalties under the Internal Revenue Code or (ii) promoting,
>> marketing or recommending to another party any transactions
EFTA00433323
>> or matter addressed herein.
>>
>>
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COMPOSITE EXHIBIT 4
EFTA00605745
•
;2/2014 Prosecutors Must Turn Ow Does In Billionaire Set Offender Jeffrey Epstein Case I Daily Business Renew
NOT FOR REPRINT
dbr DAILY BUSINESS REVIEW
a Click to Print or Select 'Print' in your browser menu to print this document.
Page printed from: Daily Business Review
Prosecutors Must Turn Over Docs In
Billionaire Sex Offender Jeffrey Epstein
Case
John Pacenti, Daily Business Review
April 22, 2014
Roy Black
Partner
Black, Srebnick, Komspan & Stumpf
Attorneys for two alleged sexual assault victims trying to negate a federal nonprosecution
agreement with biNionaire pedophile Jeffrey Epstein applauded a decision by a federal appellate
court as a triumph for victims' rights.
But Epstein's celebrity defense attorney Roy Black said the decision by the U.S. Courts of Appeals
for the Eleventh Circuit in Atlanta undercuts the plea negotiation process and attorney-client
privilege.
The U.S. Court of Appeals for the Eleventh Circuit affirmed an order requiring prosecutors to turn
over documents about plea discussions with Epstein. The decision also lifted an appellate stay on
the ruling by U.S. District Judge Kenneth Marra in West Palm Beach to allow the release of
documents to the women, identified in court papers only as Jane Doe No. 1 and Jane Doe No. 2.
The women say they were sexually molested as minors by Epstein and claim federal prosecutors
violated the Crime Victims' Rights Act when they negotiated the nonprosecution agreement in
2007.
Both sides agreed the opinion sets a precedent unrivaled in other federal circuits.
"So much of the legal area of victims' rights is breaking new grand and new territory," said Jay
Howell, a Jacksonville appellate lawyer who represented the women. "The court decision here
expands the rights of the victims and the victims' ability to discover information about the criminal
case."
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He said the women have stuck with the case out of "a fundamental sense of injustice" for the
underage victims of Epstein.
Black, a partner at Black, Srebnick, Komspan & Stumpf in Miami, said the 23-page opinion issued
Friday has wider implications in plea bargains. No longer can defense attorneys be candid with
prosecutors when trying to negotiate a plea, he said.
"This is now the leading precedent holding that plea bargain discussions are not confidential, and
now criminal defense lawyers must censor their communications with prosecutors," Black said.
"The Eleventh Circuit has ruled there is no privilege, there is no confidentiality."
Miami attorney Joseph DeMaria, a partner at Fox Rothschild and former federal prosecutor, said
while the opinion is legally correct, it could have a significant impact on the 90 percent of federal
cases resolved by pleas. He said it now is up to Congress to amend the Crime Victims' Rights Act
to carve out a safeguard for defendants.
He foresees "a chilling effect on plea negotiations where victims are aggressively seeking
information."
"If these type of plea discussions are now discoverable by victims, then it's going to cause
significant problems for the government and defendants in trying to resolve criminal cases,"
DeMaria said.
Epstein was accused of luring underage women to his Palm Beach mansion for sex. The television
show "Law & Order SVU" had a "ripped from the headlines" episode based on Epstein, who is
also known for his celebrity connections Flight logs show former President Bill Clinton flew on
Epstein's private plane 10 times from 2002 to 2005.
Plea bargain
The appellate case stems from a decision by federal prosecutors not to charge Epstein if he
pleaded guilty to state charges in Palm Beach Circuit Court for soliciting an underage girl for
prostitution. He was sentenced to 18 months in jail and house arrest.
Epstein moved back to New York City from Palm Beach after he finished his sentence.
The women contend they could have argued against the nonprosecution agreement if they were
informed before the agreement was reached.
"Our clients want to see Mr. Epstein held accountable for the numerous sex offenses he committed
against many children," said Bradley Edwards, the women's trial counsel and a partner at Farmer,
Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale.
Edwards said the documents at this point will be disclosed only to the plaintiffs and will not become
part of the public record.
Andrew Levi, a partner at Lehr Levi & Mendez in Miami and former federal prosecutor, said once
documents are in the hands of civil attorneys they can easily be passed on to news media or put in
other court records.
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;220;4 ProseaNas Must Turn Ow Docs In Billionaire SexOffend& Jeffrey Epstein Case I DaNy Business ROWPN
"It's not as if they are given to the attorney with any type of limitation attached," he said. 'We are
going to have to see how this plays out in the future to determine if this decision has a chilling effect
on the candor and possibly the effectiveness of communications by defense counsel when
negotiating a plea."
Unanimous opinion
Epstein's criminal defense attorneys, Black and Martin G. Weinberg of Boston, intervened in the
appeal as third parties. The appellate ruling was written by one of the more conservative members
of the Eleventh Circuit.
Judge William H. Pryor said the federal rule of evidence cited by Epstein in the interlocutory appeal
did not protect him against discoverability of plea negotiations.
"And even if they did, Epstein clearly falls outside its protection because he entered a guilty plea
and the victims intend to use the correspondence against the United States, not against Epstein,"
Pryor wrote.
He was joined in the unanimous decision by Judge Beverly Martin and U.S. District Judge
Charlene Edwards Honeywell of Orlando, sitting by designation.
The U.S. attomey's office in Miami argued before Marra that the victims did not need to be notified
of the agreement because the women's liberty was not at stake. It also took the position that the
Crime Victims Right Act did not apply unless federal charges were filed against Epstein.
Victims' Rights
Howell said the decision indicates how courts have come around to the victim's point of view. He
said as a state prosecutor in 1978, victims' rights were nearly non-existent
"There has been a fundamental change in the courts," he said. "It's only been in the last 30 years
that courts examines things from the view point of the victim."
He said plaintiffs attorneys have asked the Justice Department in Washington why Epstein was
offered the nonprosecution agreement but were told all decisions on the billionaire were made in
Florida.
"Why was such a lenient deal offered?" Howell asked. "Washington is supposed to be tough on
crimes against children, but the decision in this case certainly disputes that policy."
Copyright 2014. ALM Media Properties, LLC. All rights reserved.
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SOD-NY-3027571 Serial 30 —
Cris4Mmke(Rev.5-2347)
UNCLASSIFIED
FEDERAL BUREAU OF INVESTIGATION
Crisis Intake
Date: 10/12/2019
Case ID 31E-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX
TRAFFICKING
Drafted By:
Date/Time Received: 10/12/2019 06:16 PM EDT
CHILD VICTIM AND CHILD WITNESS IDENTITY INFORMATION
This document contains information regarding a child victim's or child witness's
identity, which may only be disclosed to individuals who have a need-to-know
such information by reason of their participation in the associated proceeding,
or if disclosure is necessary to protect the welfare and well-being of the
child.
JUVENILE DELINQUENCY INFORMATION
This document contains information obtained from a juvenile delinquency
proceeding involving a federally charged juvenile and may include the juvenile's
identity or information pertaining to the juvenile's behavior. The information
may not be disclosed to unauthorized persons. Release of the information is
permitted only to the extent necessary to respond to inquiries: (1) received
from a court of law; (2) received from an agency preparing a pre-sentencing
report for a court; (3) received from a law enforcement agency investigating a
crime; (4) received, in writing, from the director of a treatment agency or from
the director of a facility to which the juvenile has been committed by a court;
(5) received from an agency considering the former juvenile for a position
immediately and directly affecting the national security; or (6) received from a
victim of the juvenile delinquency or, if the victim is deceased, from the
victim's immediate family, when the inquiry is related to the final disposition
of the juvenile by a court.
Details:
On 10/11/2019, at 1:37:25 PM Eastern Time, David Shaver, date of birth
Canada, Internet Protocol (IP) address
UNCLASSIFIED
3501424-M1
Page I of6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00109778
EFTA01249768
50D-NY-3027571 Serial 307
UNCLASSIFIED
Re: 31E-NY-3027571, 10/12/2019
which resolves to
submitted an online tip to the FBI National Threat
Operations Center (NTOC) via tips.fbi.gov, reporting possible additional
information regarding Jeffrey Epstein case 31E-NY-3027571.
Date Submitted: 10/11/2019 01:37:25 PM EST
Transaction Number: 6843B0CF-340B-4EF1-831B-621E87A1539A
Threat To Life: False
Submitted Text:
I just thought despite his unusual death recently that the Jeffery
Epstein Case might still be open and there may be other persons of
interest to FBI that should become known for the purposes of further
investigations of high-profile criminal collaborators of the Late Mr
Epstein. I am basically just a random Facebook citizen that came across a
very odd post from a weak acquaintance that seemed so out of place, I
just couldnt ignore it. I already reported the post to Facebook
themselves but they dont appear to have taken any susbstantive action on
it, although they did reply to me. Here is a verbatim transcript [minus
imagery] of the post in question by Rebecca Smith, a person that you may
find of interest subsequent to reading what's below: Rebecca Smith 10
August . I did NOT participate in any underage hanky-panky on any of
the 26 DOCUMENTED flights I took aboard the Lolita Express to a known
pedophile's private island inhabited only by victims of sex-
trafficking!!! The Secret Service was "mistaken" when they reported that
on at least 6 occasions I escaped from them, ditching them to participate
in these alleged activities! 64xd83e;&fixddl4; "Clinton's presence aboard
Jeffrey Epstein's Boeing 727 on 11 occasions has been reported, but
flight logs show the number is more than double that, and trips between
2001 and 2003 included extended junkets around the world with Epstein and
UNCLASSIFIED
2
3501.424-001
Page 2 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00109779
EFTA01249769
50D-NY-3027571 Serial 307
UNCLASSIFIED
Re: 31E-NY-3027571, 10/12/2019
fellow passengers identified on manifests by their initials or first
names, including "Tatiana." The tricked-out jet earned its Nabakov-
inspired nickname because it was reportedly outfitted with a bed where
passengers had group sex with young g
Violation: Other
Violation Questions
What was the exact crime that occurred?: Jeffery Epstein Case
When did the crime/incident occur? (Please provide an approximate date
and time): Jeffery Epstein Case
Where did the crime/incident occur? (Please provide the specific
location/address if possible): Jeffery Epstein Case
Complainant Information
First Name: David
Middle Name:
Last Name: Shaver
Age:
DOB:
Additional Info:
Type: Cell
Phone:
Extension:
UNCLASSIFIED
3501.424-001
Page 3 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00109780
EFTA01249770
500-NY-3027571 Serial 307
UNCLASSIFIED
Re: 31E-NY-3027571, 10/12/2019
Account:
Type: Residential
Address:
Zip:
Country: Canada
Subject Information
First Name: Rebecca
Middle Name:
Last Name: Smith
Age: III
DOB:
Additional Info: N/A
Row is Contact Known: Facebook friends.
Type: Other
Address:
City:
Zip:
Witness Information
UNCLASSIFIED
4
3501.424-)01
Page 4 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00 109781
EFTA01249771
50D-NY-3027571 Serial 307
UNCLASSIFIED
Re: 31E-NY-3027571, 10/12/2019
First Name:
Middle Name:
Last Name:
Age:
DOB:
Additional Info: N/A
How is Contact Known: N/A
Type: Other
Address:
City:
Zip:
Remote IP:
Remote Host: api.fbi.gov
Http Referrer: https://www.fbi.gov/contact-us/field-offices/newyork
User Browser: Mozilla/5.0 (X11; CrOS x86_64 12371.75.0)
AppleWebKit/537.36 (KHTML, like Gecko) Chrome/77.0.3865.105 Safari/537.36
Latitude:
UNCLASSIFIED
3501.424-001
Page 5 of 6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00109782
EFTA01249772
SOD-NY-3027571 Serial 307
UNCLASSIFIED
Re: 31E-NY-3027571, 10/12/2019
Country: CA
Region:
City:
Postal Code:
Timezone: -I
••
UNCLASSIFIED
3501.424-001
Page6of6
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00109783
EFTA01249773
DataSet-9
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EFTA00168246
EFTA 00017790
LAWRENCE VISOSKI
Given in recognition of your successful completion of the
Gulfstream IV Recurrent - 4 Day Training Program
this Twentieth day of December
Two Thousand Eighteen
Center Leader
Aviation and Training Services
Gulfstream IV / 8556490
Notice of Resignation
Please be advised that effective upon the closing of the purchase and sale of all the
outstanding Membership Interests of JEGE, LLC, a U.S. Virgin Islands limited liability company (the
"Company"), pursuant to the provisions of that certain Membership Interest Purchase
Agreement, dated May 2, 2019, by and between Jeffrey Epstein, as the Seller, and Aviation
Development Group, as the Purchaser, the undersigned, Lawrence P. Visoski, Jr., hereby resigns
as the Manager of the Company.
Dated: June 12, 2019
Lawrence P. Visoski, Jr.
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Total 1 Total Total
_
Engine #1 Starts: 147L1 N1 cycles • N2 cycles '
(Cycles are recorded from aircraft IlDs panel)
Total: 6 / -`>a-
Engine #2 -7 47-, p/---Starts7144.9 N2 cycles, : _N2 cycles -
+
Total: _
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
1.017 4,7
55-7 - Frgy
FA y-sisy -t53
SAY -7 - (11 7 t(3
,
EFTA_00017794
EFTA00168250
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
Pee01/0 E"-XliAliq
Date: 3 VFlight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Rap ORIM0
trb /
e/CMA PA-17 ) IL co
- SS 1 • e_ FSoZmiA.
EFTA_000 17795
EFTA00168251
Shmitka Air, Inc. Flight Logs N722JE
Serial a760750 S76C++ Larry Visoski cell
- • s-i7,-----7--J IR& 0 ""`*--
Date: & - ,P,v2 -// To: Sill --ASi-≤"H-- 'om: -711)
- /1-t I,PV Pou;,.,o,WL
Trip # 33 1
Pilot:La tz'ay Vf4.,/g.
--- Co-Pilot: ,A),. ilff--,A0-vid•
Airframe: 6, ,, . / Landings: i 44.
+ .3,O + e--/
Total 64e ( Total 7 .5,6 Total
Engine #1 -614,1 Starts: N1 cycles N2 cycles /
(Cycles are recorded from aircraft IlDs panel)
Total: b9 I
Engine #2/,-.76, / Starts' NQN2 cycleF, N2 cycles
Total: _ / 44 =5'
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
•AA,•1 •
- 7 4 45 P
771.6Q- IroPv
EFTA_000 17796
EFTA00168252
Shmitka Air, Inc. Flight Logs N722JE
Serial U 760750 S76C++ Larry Visoski cell
Date: c>9 - q -I/ — 577 14I - TS'Y - L J-Sd
To: €'77-- XS.) -STT- LS:sgm
Trip # 3a Pilot:, Co-Pilot: ,
Airframe: -6 Co Landings:f 3 k
g
Total Total / T 6 Total
Engine #1. - Cc, 6 Starts: 3 V N1 cycles N2 cycles / ' (
(Cycles are recorded from aircraft IlDs panel)
Total: 6:Z
Engine #2 L(74(6, Starts' } cycles, : _N2 cycles —
7fg + e
Total: _ CA / _ 7e2
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017797
EFTA00168253
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 576C++ Larry Visoski cell
Date: 1u /atm To: rr ST--
/
Trip # 3i Pilot:i D ?cnto...i.- Co-Pilot: 1-.4.V‘zosie--1
Airframe: 63. 6 Landings:13 q
4
Total Col). Co Total 1 3? Total
Engine #1 - (0 3.4) Starts: ,124 N1 cycles • N2 cycles '
+ © 3 (Cycles are recorded from aircraft IlDs panel)
Total: !A.G.
Engine #2 Co3.ce Starts. ,13} N2 cycler,` -_ N2 cycles - - •
+ 11.0 + 3
Total: _ t
Fuel Burned: Fuel Purchased: 5.-Deo—
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017798
EFTA00168254
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
374/` Sd 7-UM — 4.8J,••!s
Date: / —7-1/ TO: 77i,i Area-fit -24.1ro m:
Trip # 31P. 0 Pilot: itratki Co-Pilot: M.47,-146-vwc-k
Airframe: 6,9 c•.3 Landings: /
+ •/ •3
Total 63. 2 Total _l_s_73443s) Total
Engine #1 -,6,?,3 Starts: i 2 N1 cycles I/L, 9 N2 cycles .49/. Ff
+ 1. 3 + 60 (Cycles are recorded from aircraft IlDs panel)
Total: 63;C,,,
Engine #2 4 c2. Starts cycler,a,0 N2 cycles , 03.7
+ /3
Total: _
Fuel Burned: Fuel Purchased: i/.4
Take off time: 7:44 -ki Landing time: :42.01 Flight time: /4- /Y
Passenger: kie Passenger: d6.6 ZA.4.3
Passenger: ‘ovezi4,2 .2.102epsoi Passenger: J /4-c 6" 1• 46,4)
Passenger: #6014,-) firt6 Passenger:
Passenger: 4PacC Passenger:
EFTA_00017799
EFTA00168255
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C#4. Larry Visoski cell
Date: kiW(C) 2..,. .)- 11c.04Q41,-om: f•VOtrAP..A -04.gfle -J-44-4)
Trip # c2- Pilot: c.2 . vacy. Co-Pilot: p1/4-4 0,4Z
Airframe: A. / Landings: ./gD
+
Total Total Total
Engine #1 -6;C/ Starts:/rya N1 cycles . • N2 cycles i
(Cycles are recorded from aircraft IlDs panel)
Total: 2 ,.3
Engine #2 Starts- MO N2 cycles- V _N2 cycles — .
+a 1'4
/7 + 5
Total: _ /OZS.'•
Fuel Burned: Fuel Purchased:
/PON* TiRitlf c-S44— 67/
5—P,
Take off Me: .7.A94.4 Landing time: Flight time: (4,:e) 00/1 6-4.441,.
Passenger: 13 uri.A.i 57,7 t4 Passenger: —1-45 6..c7
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017800
EFTA00168256
Shmitka Air, Inc. Flight Logs N722jE
Serial # 760750 576C++ Larry Visoski cell
Date: ic; -020 -20/0 To: ,SH - 413-$ 1-5j -C4+-1 J-C1+
Trip # A Pilot: "Ztos Al Co-Pilot: A/ lAiLlteof vc12
Airframe: 5- 4-1 Landings: //I_
+ •b + e
Total 6 0. Total /O2- d Total
6/ • 6,2
Engine #1 C6 • / Starts: 1/.1 N1cycles /0 3 . 9 N2 cycles /O6. ,
(Cycles are recorded from aircraft IlDs panel)
Total: 670 /02.O
Engine #2 5-6 . ( Starts: /42 N2 cycles/O C.3 N2 cycles /0P.1
-/-
+
Total: //, 0 • I
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017801
EFTA00168257
Shmitka Air, Inc. Flight Logs N722JE
Serial a 760750 576C++ Larry Visoski cell
Date: q- QC) -10 To: , -,--i:•-",(-SPShT- From: Viii. -71.4
.___— :-.
.2,1 -
Trip # 0? -7 Pilot:j1/50,S Co-Pilot: A/PA/4
Airframe: 3-(7z, Landings: in6
+ /c21- + C:
Total 5 ‘e / Total //r . Total
9o?. 95; 5—
Engine #1 6'--(4 Starts: /6,6, N1cycles N2 cycles
(Cycles are recorded from aircraft IlDs panel)
Total: 6 6, / //o/-
( 5743
Engine #2 V. Starts: 0,, N2 cycles N2 cycles
/// - + G
Total: 5 -6 , //e9,
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017802
EFTA00168258
Shmitka Air, Inc. Flight Logs N722JE
Serial 11760750 576C++ Larry Visoski cell
Date: 1' -19-10 To: cri14. From: 59/ - LS(/
Trip # oZ Pilot: Jitefas/2' Co-Pilot:
Airframe: Landings: /63 5
Total Total ;o7 Total
Engine #1 cc/ Starts: /O c N1cycles N2 cycles
+ (Cycles are recorded from aircraft 1lDs panel)
Total: 97. / 0 4O
Engine #2 91 Starts: /0.3N2 cycles N2 cycles
. +
Total: 5 119 /O(
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017803
EFTA00168259
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
Date: -1O / To: S+4— 4S -f From: S 4- f'
Trip # c:2 )Xv_s/2 Co-Pilot: Ni&iias.
Airframe: 5:3,7 Landings: "77
+ :7 + Co
Total 54/, .7z Total /6 c - Total
Engine #1 53,7 Starts: 95' N1 cycles N2 cycles 0.
+ (Cycles are recorded from aircraft IlDs panel)
Total:5-` • z-7" /0
Engine #2 53,7 Starts: () N2 cycles 27,; N2 cycles
'7 +
Total: 5- 51, /OS
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017804
EFTA00168260
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750576C++ Larry Visoski cell
Date: isia/ao,c, To: -msg.- - Lis.% From:
Trip # a4 Pilot: I— • •tzs ict Co-Pilot: Ib.RoTttct,_
Airframe: sz.cc Landings: 1 Di
Total ss Total Total
Engine #1 s-2.9 Starts: cis- N1 cycles N2 cycles
+ O, (Cycles are recorded from aircraft IlDs panel)
Total: ss
Engine #2 -s-2. .1 Starts: "4 N2 cycles N2 cycles
o
Total: 91
Fuel Burned: cwo Fuel Purchased: 70 Geri_
Take off time: 0745 Landing time: 1‘, co Flight time: O.4.4'1
Passenger: 48— 4- 6 Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017805
EFTA00168261
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 5760+ Larry Visoski cell
Date: -dor /to To: - t-ir L-5,1 From: ms-c
Trip # 23 Pilot: Co-Pilot: L. V ISc.z5KI
Airframe: sa.--1 Landings: let
+ 6,2 + a
Total 52:i Total 70 Total
Engine #1 52 Starts: ci3 Ni cycles N2 cycles
+ c.) a + 2 (Cycles are recorded from aircraft IlDs panel)
Total: 52.9 45
Engine #2 sari Starts: C13 N2 cycles N2 cycles
+
Total: ca. cr 94
Fuel Burned: 2 Ifs Fuel Purchased:
Take off time: to Lis Landing time: HOT' Flight time: 0r12
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017806
EFTA00168262
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
Date: yid.. J io To: ---cts-r From: -ris-r
Trip # as Pilot: Ntstes-wt Co-Pilot: b. ?onkel/.
Airframe: ra .3 Landings:
0.4
Total a -7 Total Total
Engine #1 5-c3 Starts: 9a N1cycles N2 cycles
o .L1 (Cycles are recorded from aircraft IlDs panel)
Total: 57 71 '(3
Engine #2 sa.3 Starts: 92 N2 cycles N2 cycles
+
Total: S2.
Fuel Burned: 4, is" Fuel Purchased:
Take off time: 1 25:5 Landing time: as l ct Flight time: v g
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_000 I 7807
EFTA00168263
_ Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
Date: / Icy. )to To: -ns-r- From: rAtsPt
Trip # al Pilot: L. \Aosv..% Co-Pilot: t). Vermne"
Airframe: so .9 Landings: 4c,"
1.4
Total sa .3 Total L Total
Engine #1 son Starts: cli N1cycles N2 cycles
+ IA + 1 (Cycles are recorded from aircraft llDs panel)
Total: 52.3 1 2
Engine #2 So.4 Starts: qi N2 cycles N2 cycles
+ 11 +
Total: -'2.3 412
Fuel Burned: 1O23 Fuel Purchased:
Take off time: -atoq Landing time: aaa-zr Flight time: 14-4
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017808
EFTA00168264
Shmitka Air, Inc. Flight Logs N722JE
Serial it 760750 576C++ Larry Visoski cell
Date: 8 /or— I Jo To: ta pe From: tAt.ei
Trip # 2O Pilot: L, Vr3cstct Co-Pilot: "I>. Rcarmeti—
Airframe: or. 4 Landings: 62
+ to + I,
Total SO .4 Total 63 Total
Engine #1 4g,4 Starts: go N1cycles N2 cycles
+ 2.0 + 1 (Cycles are recorded from aircraft IlDs panel)
Total: sz).1 cti
Engine #2 n.7 Starts: It N2 cycles N2 cycles
Total: 56 9 91
Fuel Burned: ,Has Fuel Purchased:
Take off time: ti 59 Landing time: aaO) Flight time: acf 0I
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017809
EFTA00168265
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
Date: .% )06 1,0 To: wirsfy From: ret4cr
Trip # t9 Pilot: L. VISDSK Co-Pilot: b. Rerricts_
Airframe: /4-7,q Landings: 6,1
¶3
Total gel Total 4 Total
Engine #1 Li-r..4 Starts: II N1 cycles N2 cycles
5 (Cycles are recorded from aircraft IIDs panel)
Total: iit./ 90
Engine #2 'it Starts: t N2 cycles 142 cycles
+ 1.5
Total: Jor.`i 90
Fuel Burned: it 051 Fuel Purchased:
Take off time: 1c34 Landing time: I-WY Flight time: 1
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017810
EFTA00168266
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 576C++ Larry Visoski cell
Date: % l oco lio To: YANET-- From: Kpist
Trip # %I Pilot: L. Vitas 4 Co-Pilot: b: Z oa -niets—
Airframe: Lls.q Landings: 6,c)
R. b
Total Total 1 Total
Engine #1 t .4 Starts: -Ts` N1 cycles N2 cycles
.2 a + 1 (Cycles are recorded from aircraft IlDs panel)
Total: vi
Engine #2 4s.4 Starts: -re N2 cycles N2 cycles
+ 30 + 1
Total: iity
Fuel Burned: iqsa Fuel Purchased:
Take off time: %ve) Landing time: 431 Flight time: Go- IDS
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_0001781 1
EFTA00168267
Shmitka Air, Inc. Flight Logs N722JE
Serial ft 760750 S76C++ Larry Visoski cell
Date: To: alb From: Ppr
Trip # / 7 Pilot:0Z. icsos /1 Co-Pilot: Lo5c
ris./.#6 1.-41,„0,1c.
Airframe: 41 ci , 3 Landings: S7 --reati
+ 1L ( + S
Total 4. 6 - . q Total 60 Total
Engine #1 yis Starts: 11 N1cycles N2 cycles
+LL 3 (Cycles are recorded from aircraft IlDs panel)
Total: LIC SP
Engine #2 4 (1,3 Starts: a C N2 cycles N2 cycles
+ t• + 3
Total: z/E, k
Fuel Burned: Fuel Purchased:
Take off time: Landing time: Flight time:
Passenger: Qicen) CHAD 860RME Passenger:
Passenger: iideciA.5 tg9 Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017812
EFTA00168268
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
‘‘Esi-
Date: /5" To: k/D/3/ r0,46,1Peik From: 06FA Si L/ciZ5.ey 04,i
Trip # /6 Pilot: ) • i4,S0611 . Co-Pilot: A_ ii;,&-y
Airframe: T -0 Landings: 56
+ ,3 + /
Total .77V , 3 Total 57 Total
Engine #1 11-1/ e Starts: /? N1cycles g',3 N2 cycles 7 (:?
, 3 (Cycles are recorded from aircraft IlDs panel)
Total: 3 is--
Engine #2 144 D Starts: g Nt cycles t (L • t N2 cycles 1,,c‘ .3
+ ,3 + 1
Total: 4/ 3 3C
Fuel Burned: 46 Fuel Purchased: /0 ‘Alle.tr,J
Take off time: ,,?-4f3p41 Landing time: a5-9,41 Flight time: "/"/P /4/;;ti
Passenger: --te — Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
C
0-450,09,1 0A- F/De-2.1/61
6:1
EFTA_00017813
EFTA00168269
Shmitka Air, Inc. Flight Logs N722jE
Serial # 760750 576C++ Larry Visoski cell
sheb.2..cel
Date: 57/5//0 To: 04,Flt L.4.01- From: U,,F,4 5/;
;4•442A! /)/
Trip # / 5 Pilot: .2- Vso5A4 Co-Pilot: fi 17)4e7
Airframe: SO ..7 Landings: 56-
+ ,,,3 + /
Total $1 r 0 Total 54 Total
Engine #1 43:2 Starts: 3 N1cycles N2 cycles
+ .3 + (Cycles are recorded from aircraft IlDs panel)
Total: / 4 C
14 ,(
Engine #2 `713,7 Starts: N2 cycles N2 cycles
,3 +
Total:
Fuel Burned: 4C, Fuel Purchased: /DO 6416,445 °..3,Fe', 41
2 _ray.
Take off time: A 5,)pm Landing time: as• 16 pm Flight time:
Passenger: eX1/ 2 y gbAlb Passenger: 344/
eil40,40/;44), /171.≤6.44t. _
Passenger: vF .1-4.406,,,e7 et Passenger:
Passenger: ele#,I ex-76 SCS Passenger:
Passenger: /54-X Passenger:
64.3bAj4 -)' -itt
47 e vii • Dc
EFTA_00017814
EFTA00168270
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
3+421 6,1.&mat) =IAA&
Date: 3//51/0 To: /*FA MAA.) From: ,,2,5(51 4.A.
Trip # /4 Pilot: I. V/ISOSA Co-Pilot: 17 'ray
Airframe: f 7 Landings: 6
r;?, 6 1
Total 4/3 , 7 Total 55 — Total
Engine #1 qie 7 Starts: Ni cycles N2 cycles
A + / (Cycles are recorded from aircraft IlDs panel)
Total: 43, 7 ,k.3
Engine #2 5//, 7 Starts: N2 cycles N2 cycles
0 + /
Total: 5/3. 9
z
Fuel Burned: 97.0 ABS. Fuel Purchased: /1/ cAzio,u5 * Fa --
Take off time:/6 zAlist Landing time: AR:O1qm Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
C 1 p 6A)/ 4i
EFTA_00017815
EFTA00168271
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 576C++ Larry Visoski cell
Date: 5- — To: SST From: C.L- 71-
Trip # I3 Pilot: r ? 0,50 3/ Co-Pilot: /
Airframe: Landings: 53
/ •7
Total Total 5/ Total
Engine #1 1--D • L Starts: / N1cycles N2 cycles
+ + l (Cycles are recorded from aircraft IlDs panel)
Total: iqe 7
Engine #2 qe• 0 Starts: '7 N2 cycles N2 cycles
/.7 +
Total: 7,
Fuel Burned: I 1 50 Fuel Purchased: is, / AL.t.esitri
Take off time: eof Am Landing time: 9: 442 /am Flight time: / f 41 6 —
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
C(2
EFTA_00017816
EFTA00168272
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 576c++ Larry Illsoski cell
Date: S- To: C 4,Atote4eFrom: ROL( 2.adnj.
Trip # Pilot: J 14 So s A), Co-Pilot: lqA.,Dgeet)
Airframe: 39, d- Landings:
•?
Total 7 -O, O Total Total
Engine #1 3 g' Starts: Pó N1cycles N2 cycles
+ g + (Cycles are recorded from aircraft IlDs panel)
Total: (71"
Engine #2 3 9, a- Starts: N2 cycles N2 cycles
,F +
Total: 416. e 67
Fuel Burned: 1O(3 Fuel Purchased: /076- 44/10AA5
Take off time:;*3
. PM Landing time: &-.O -tom Flight time: -/-57
Passenger: &eef. 0 o (&) Passenger:
Passenger: )OA), ( 0 ,-, le6-) Passenger:
Passenger: Je$14/s-'in't .:. A..1-, c,g, Passenger:
Passenger: Passenger:
EFTA_00017817
EFTA00168273
Shmitka Air, Inc. Flight Logs N722JE
Serial 5 760750 S76C++ Larry Visoskl cell
Date: '5 - 14 --/6 To: PD L4 From: qixi.
Trip # 453s' Co-Pilot: 14,-.DR62.3
Airframe: ' F. 9 Landings: S/
74
+ , .....) + 1
Total Yi • (."? Total S ,)-- Total
Engine #1 3q-,(-? Starts: 7 9 N1cycles N2 cycles
+ 3 (Cycles are recorded from aircraft ilDs panel)
Total: 3V,g
Engine #2 3F-• q Starts: (o N2 cycles N2 cycles
+
Total: gq' “)'
Fuel Burned: 3: 16-pot Fuel Purchased 4V-:12,
Take off time: 3: iC)Ort• Landing time: 3: 3 f Pte. Flight time:4-1(/
Passenger: COA.J•4-;CsAv Passenger: P,91(
Passenger: r )41)E 614 0 Passenger:
Passenger: P/474 Passenger:
Passenger: P,g-/ Passenger:
EFTA _00017818
EFTA00168274
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 S76C++ Larry Visoski cell
Date: f7
. 7/SI // 6 To: i2)4:( ?At Zr, NC:. From: eLY C/7A4t/&14. A).L.
Trip # /0 1//50.5,1/ Co-Pilot:
Airframe: / Landings: 50
Total 3 g. 9 Total f±7 f Total
Engine #1 ( Starts: c7i/ N1cycles N2 cycles
+ (Cycles are recorded from aircraft IlDs panel)
Total: 3 7g
Engine #2 -3 I Starts: 4( N2 cycles N2 cycles
, +
Total: 3S). S
Fuel Burned: Fuel Purchased: /0 4/4/torah T/V-`-")
Take off time: 6' 26/4,,k Landing time: 7. L:s" Flight time: -4- 9-t —
Passenger: dc.A.3 Passenger:
Passenger: dpA,..A.c Passenger:
Passenger: aeell DuZe P'24-$ ,°,-.1•4' Passenger:
Passenger: Passenger:
EFTA_00017819
EFTA00168275
r
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 576C++ Larry Visoski cell
Date: 5 110 To: e 47i " p4c /NC From: 5.52- en, ~SZ s7
N.C.
Trip # oLi.,/2/ Co-Pilot:
Airframe: :3L, Landings: 4
Total 3Y • / Total 57) Total
Engine #1 36 • 5 Starts: 7 7 N1cycles N2 cycles
(Cycles are recorded from aircraft Ws panel)
Total: 31' I 7
Engine #2 ?ice • .5 Starts: L 3 N2 cycles N2 cycles
+ (4
Total: .3 / /-/Av46 'ci/7.5.1°
Fuel Burned: iC)- Fuel Purchased:,/5? Qi/it-76
Take off time: 1:/t, pm Landing time: g -C941/1 Flight time: /74 37
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_000 I 7820
EFTA00168276
Shmitka Air, Inc. Flight Logs N722JE
Serial II 760750 S76C++ Larry Visoski • cell
65Zss
Date: 5 i/ To: From: PM: 4tot R(.4
Trip # Pilot: IA •,,S09 Co-Pilot: 4#24
Airframe: 3'4 7 Landings:
Total 3 6.5 Total 4 cr Total
Engine #1 3 4-1, 7 Starts: N1 cycles N2 cycles
+ (Cycles are recorded from aircraft IlDs panel)
Total: 31!0.5 77
Engine #2 3'7( -1 Starts: 4--%(;/ N2 cycles N2 cycles
Total: 36
Fuel Burned: /.' ,'; 7 •=ks Fuel Purchased:
4//202A Fi- 14RO '0 170 • eg
kid/46;w
Take off time: A4.: Slph Landing time: 4; `707PPT Flight time: / 71 5-6
.0.,pesmr /
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_00017821
EFTA00168277
Shmitka Air, Inc. Flight Logs N722JE
Serial # 76O750 S76C++ Larry Visoski cell
Date: /7"; h /10 -}
To: P/31- S (--'f From: P&L - rf -)-1-
Trip # 7 pilot; 1, ,s-,,s//‘ Co-Pilot: '47'4 (r/‘
Airframe: :.-3 3 .471 Landings: q 5
+ / 3 + 3
Total 3 ,7 Total 7• g Total
Engine #1 33.4 Starts:173 N1 cycles N2 cycles 6, 3- `/C-
+ 7.3 + (Cycles are recorded from aircraft IlDs panel)
Total: L/-
Engine #2-2,7.-3) Starts: c9 N2 cycles 6. -S: / ,N2 cycles 6 /, .4)
+ :3 +
Total: 314,7
Fuel Burned: Fuel Purchased:
Take off time: /2- OO Landing time: a - (1.-& Pn'k
- Flight time:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
Passenger: Passenger:
EFTA_000 17822
EFTA00168278
Shmitka Air, Inc. Flight Logs N722JE
Serial # 760750 576O4 Larry Visoski cell LVJET@AOLCOM
Date: 17 1 ,a; - 2C it) To: Par From: Z.NC-- - RiiTE
Trip # Pilot: I. Vito!: Vi Co-Pilot: PoliteCt
Airframe: :3R. 2' Landings: '13
,Lc
Total 33 . Total `4 -45— Total
Engine #1 3.2 S Starts: -2/ N1 cycles 53.3 N2 cycles 5—E-, /
I
oc (Cycles are recorded from aircraft IlDs panel)
Total:
Engine #2 322. f Starts: 5, N2 cycles • / N2 cy