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EFTA01136992.pdf

DataSet-9 Unknown 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 2 EFTA01136993 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 3 EFTA01136994 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 4 EFTA01136995 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 5 EFTA01136996 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 6 EFTA01136997 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. 7 EFTA01136998 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 8 EFTA01136999 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 9 EFTA01137000 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 10 EFTA01137001 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 11 EFTA01137002 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 12 EFTA01137003 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. 13 EFTA01137004 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). 14 EFTA01137005 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 15 EFTA01137006 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 16 EFTA01137007

EFTA00074322.pdf

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

EFTA00154690.pdf

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

EFTA01779205.pdf

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

EFTA00161474.pdf

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

EFTA00147946.pdf

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

EFTA00172826.pdf

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

EFTA01140114.pdf

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

EFTA01245688.pdf

DataSet-9 Unknown 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 EFTA_00058007 EFTA01245688 FD-302a (Rev. 54-10) 50D-NY-3027571 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 Page 3 of 6 CONFIDENTIAL EFTA_00058009 EFTA01245690 FD4inallim5440 50D-NY-3027571 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 Page 4 of 6 CONFIDENTIAL EFTA 00058010 EFTA01245691 FD-302a (Rev. 5-&t0) 50D-NY-3027571 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 3501.054-008 Page 5 of 6 CONFIDENTIAL EFTA_00058011 EFTA01245692 FD-3O2a (Rev. 5-8.10) SOD—NY-3027571 ConnnueiteofFO.302of (U) Interview of on 11.21.19 ,o, 11/21/2019 paw 6 of 6 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. 3501.054-008 Page 6 of 6 CONFIDENTIAL EFTA 00058012 EFTA01245693

EFTA00727881.pdf

DataSet-9 Unknown 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

EFTA00305695.pdf

DataSet-9 Unknown 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 EFTA00305696

EFTA02728862.pdf

DataSet-11 Unknown 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 09/12/2019 Page312 Agency to Agency Baguet: 19-411 P5'..CONFrobITIAL SDNY_GM_00330325 EFTA_00203051 EFTA02728862 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 09112/2019 Page 313 Agency to Agency Requet: 19-411 CONFIDENTIAL SDNY_GM_00330326 EFTA_00203052 EFTA02728863

EFTA02539710.pdf

DataSet-11 Unknown 3 pages

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 EFTA_R1_01688279 EFTA02539711 EFTA_R1_01688280 EFTA02539712

EFTA01099380.pdf

DataSet-9 Unknown 7 pages

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 EFTA01099386

EFTA01113966.pdf

DataSet-9 Unknown 10 pages

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

EFTA00433323.pdf

DataSet-9 Unknown 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. >> >> EFTA00433324

EFTA00605745.pdf

DataSet-9 Unknown 6 pages

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." hap //wwdailybusinessraiew.conts/Saieillle? c= Mide Cachildpagenernez DBR%2Fivticle_C%2FAitieletaFLayauts%2FPrinterfriendly&pag enamoFALM.. 1/3 EFTA00605746 62/2014 Prosecutors Must Turn Os Does In Sillioneire Sex Offender Jaffrey Epstein Case p Deily Business Retw 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. tap JAwnv.daidOxninessredescorrics/Satedite?centicre_CarieldpagenarnegOSP%2FArticle_C%VArtnkletiaFlayauts%2FPrinterFnenly•Spag enarne=ALM 2/3 EFTA00605747 ;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. httphnv&dailyausinessreu tecakticle Cectildpagenarne=DBRVo2FArtitie_C%2FArtiee%2FLayautsti2FPrinterfnenlySpagenantemALIA 3r3 EFTA00605748 Sirtet-1 Appeals Cart Mies in Faux of Crime Victims Rights in Registered Pedophile Jeffrey Epstein Case p PRLog PRLOG Press Release 0 strthation Soso 7 aF. ir , SuomnPress Release Submit Free Press Release Journalist Account PRNewswlrc PR Home Latest New• Feed< Alerts Appeals Court Rules in Favor of Crime Victims' Daily News Country News Rights in Registered Pedophile Jeffrey Epstein Case rumHotntallly : LC ariti of Assn 1%.tr.azira Ataiits ben of me wynn3m In a landmark decision, the US Court of Appeals for the Eleventh Circuit Court on Ins a BakeliouSe.htalel April 18. 1014, ruled In favor abaci crime victims represented by Farmer Jaffe b2021S1109 Vasellk)da trot:I.:0c '0' 1/aPed Kinceoin WelssIng Partner Brad Edwards and his co-counsel. Paul Cassell Cnuem CO Co/lei-um •" FOR tumEOMT F RSEASE ProularJOurnaldFMn F Mare COLPOfr'” Nails, &II arincrieS New Pace (Press Re lease) -Apr. 22, 2014 • FORT LAUDERDALE, Fla. —Contact Wait Etccuse Vas Brad Edwards, Fanner, :ate. Wessling, Edwards. 12212:818100.221811 Edicts & Lohman. P L. Custom Tote Bag t> Peuanal and AnaMics Recruitment Names Aaron gi a saminaggiaz ukt NI News Mstapant Wnners 44inamced 10( Eidusne News Like what you see? Get up to 25% off. Tardt aanthollarAimel S549 First Soundtrack Contest Appeals Court Rules n Faker of Cnme Victims' Idia2114 Rights in Registered Pocbphilo Jake/ Epstein Weil* News r 711 We Tu P.t Su Sa Case Fevestnan Teams and 2 1 made Stars Unite at Soot ela.191.4 In a landmark decision, the U.S. Coo of Appeals Ride XP a Further Cantor Ellauvi for the Eleventh Circul Can on April 18. 2014, Sunni:in and hymnal" - Ned In horn or two crime Maims represented by 6a64 Mews Fanner. Jaffe. Weiss rig, Edwards. Fistos puking it Solar to See a Lehman Partner Brad Edwards and his co-counsel. Pad Cassell. Ronald N. Boyce Presidential Came .n Clwa00 at Goncia Professor a Criminal Law - S.J. Chimney Cottage ci Law at the UnikerSity a Utah the ruling uphold the Tanno Sudesent . 5750 news District Court which ordered the United States Attorney's Dace lo provide the 'Action and their *rheostat the large kolume of carespondonco exchanged between Jeffrey Epstein and the Gonernment tar-kin/4 Island trier feslival In Fyn Bloont • that resulted In the goirerrrnent electing not to Federally prosecute Epstein for his many sexual crimes t256 Mews against children. Attorneys Edwards and Cassell argued the case before the Etowah Circuit in eSegfERS ASusnensn February. against attorneys Roy Black and Martin Weinberg Howl kw Young Molts - 826 news The case imams a federal criminal imestigation that resulted in the Federal Gokornment leaning Out Brenner Bros 6I isa Nicola Jetrey Epstein and certain co-conspirators sexually abused dozens and dozen of minor girls In West CoSoction Runways/non Palm Beach. Florida. Epstein ultimately reached a plea deal. under which he plead gu fly only to a stale tarmatliflfikialtleAch local modals • 734 news charge of procuring a minor for prosbtution in exchange for the Federal Gokemmenl agroeng ma to pursue federal sex crimes on behalf of more than 40 Uctims. Represented by Attorney Brad Edwards POT 22 2014 Nem and Pad Cassell. Iwo of the guts sought to hake the ;Sea deal cyst out because prosecutors had not informed them of what was happening arid had taken steps to conceal the peculiar plea arrangements. The yams moved to hake access to the conespondence between prosecutors and defense attorneys to prow their case. The Ele'.enlh arca; ruled Mal that the kictims were wheedle hake access to the matenals. Agreeing with Attorneys Edwards and Cassell. the Elekenth Circuit mad that the communications were not priideged or Mumma barred from distribution. The Elaenth Circuil explaned that the %foams should 'entry an esiCenttary benefit from the osclosure of plea negotiations to prow where the United Slates Waned thee rights under the [Owns Victims Rights) Act' Upon literrang 01 the ruling Allomey Brod Edwards stated: The Worn, hako bight hard for almost 6 years now lo team why the person who molested them and many other children was ultimately allowed to Yw abate the law and mold being held accountable for Ns crimes. rm pleased that the Elokenth Circuit has made this ruling which will bring the actims one step closer to knowing the truth. Wealth and power should not immunize anyone Iran punishment be harmful sexual acts against children, a the circumstances when it does, the mourns should at least haw access lo the explanation why, These documents should begin to explain: Farmer. Jaffe. Westing. Edwards. Fisica 8 Lehrman. P.L.. a Forl Lauderdale LW-gallon ton. focuses on Consumer Class Actions. Persons Wray. Wrongful Death. and WhisUeaave* Suits (qui tam). The km 'salad flared at Additional intonation about Brad Edwards. or Fanner. Jane. Welssing. Edwards & Lehrman. P.L. may be obtained tom IMO fm's webs'te al ONO oallitCauSliCe Cnns'aliorroys brad-ecksardst laiirt‘Yee M rSeandassault cc 'n or Nip A-my PsalltssulliCe.COM. Nip //werivalog .org/12313086-appeals-cast-rules-in-Imer-olairre-uctims-rights-in-registered-pedcphilejeflrepanlein-anettml 112 EFTA00605749 512/2018 Art%is Cart Rules ir Fawn'. of Crime Victims' Rigets ir Registered PeelaphileJeffreyEpstein Case' PRLog Contact BARD Marketing . "1.abard'1111,kil11,11;n41, —End — Follow Email Embed PDF/Prall VI t El Contact Email Cat LIC1Purer •"04syclmarkelingtom✓ Scarce • BARD Madating Cityrrown . FOIL a “der ate - Forida • United States Industry : beget Tags :Bind Edwa•ds. Jeffrey E ps loin. Crime Victims Rights. bum or lane weissing Shortcut : prop org/12313086 Disclaimer. Is1111Ors Of 1110 press I °bases are seielytesponsible or De content or Ned press releases PRLoq cant be held liable br the content posted by miters PEIDOIAbilse Latest PreSS Releases BY "Itgatatkni n • Azorner maiwtssrna ;firms Team Fame, Jame We's s P.11,1,10010 m 7r Atindal CMOS 841 Cartlig • another Adam MorowiaJoins Former Jere Wen sing • amen /comer Rotnn DonskvSnag et Ne 19th Cscud Bench Bar Cortioreecg • Mona/ G.imi lo Sponsor Justrale Diabetes Research Fouhdabon s Casino NoN and Arbon • anomestembeel 7amiaano Co-Clia•od the A14/ 5 Ronan Pen one' SlyeaM 711N nOaxecy Competition Trending News... • Pi *Connell el F.µ$d Panneis 01SCUWIS Gluten's nnact on Memory Meets ;OHO • eel RevnMes From New Pete Beene, Book to be Donated to Hudson Pow. 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EFTA01249768.pdf

DataSet-9 Unknown 6 pages

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

EFTA01192381.pdf

DataSet-9 Unknown 1 pages

Firefox file Ldit View Himory Bookmarks Tools Window Help It t ••• 40 Mon 3:40 PM CL • I/. El ft fecy epstein - Cco444 S •vLy https twv.w.google.tomi searchki etre 13' ieffrey epstein CI i It Cr IS M sr) m Li km a Most Visited •• a Conk Images NMI= (6) -Memo... n Yelled finance - ocGoogle News g The New York Ti. N.1 Nathan wolfe - je... 4 Getting Started Wob Images News Shoppng Vdeos Mote - Search tools z About 3.290.000 results (0.43 seconds) 4 2014 ..:lzEdzsz Laa Jeffrey Epstein - Wikipedla, the free encyclopedia olph, From Google Contacts en.wikipedia.orgkeriki/Jeffrey_Epstein Wikipedia - ,r. I can see these results Jeffrey Edward Epstein (born January 20, 1953) is an American financier and science • 7 and education philanthropist. He worked al Bear Steams early in his Life - Financial career Science funding - Solicitation of prostitution _Landing_ -; Jeffrey Epstein 0e-144/ Jeffrey Epstein: Sex Offender, Yes. Billionaire, No. - Forbes Update your profile wiwzforbestorni.../Jelfrey-epsteln-sex-offender-yes-big... • Forbes - by Clare O'Connor - in 167 Gcogle• ordes 14 Fob 28. 2011 Palm Beach pervert Jeffrey Epstein is all over the news today. Other: [email protected] Vl thanks to a series of stories in the UK's Daily Mail linking the convicted Home: [email protected] ages.jpg pedophile ... Home: 340 775.2525 Mobile: 212.533.3739 Jeffrey Epstein: International Moneyman of Mystery nymag.cominymetrolnews/peoplarn_7912/ - New York Magazine - Home: 6100 Red Hook Quarters 00802-1348, United States Set rSe He's pals with a passel of Nobel Prize-winning scientists. CEOs like Leslie Wexner of 64 the Limited, socialite Ghislaine Maxwell. even Donald Trump. But it wasn't ... Home: 6100 Red Hook Qtr, 8-3, new York, NY 10021, United Stat 0 Horne: 9 e 71st, new yak, NY 1 Jeffrey Epstein, MD, FAGS: Top Plastic Surgeon vnvw.drjeffroyepstein.coml - Dr. Jeffrey Epstein is a triple board certified plastic surgeon specializing in both hair transplant and facial plastic surgery. 28 of 1 • 6 Billionaire Jeffrey Epstein: I'm a sex offender, not a predator ... nypost.comr..billionaire-jefhey-epsteinrtm-a-se... - New York Post - by Amber Sutherland U Feb 25, 2011 - Bilionaire pervert Jeffrey Epstein is back in New York City — Screen Shot images_upg 2013-...7.29 PM and making wisecracks about his just-ended tail stint for having sex with an ... o images Bill Clinton identified in lawsuit against pedophile Jeffrey ... - Daily Mail - Mar 19, 2014 . Bill Clinton's friendship with Jeffrey Epstein, who served time in 2008 fo- having sex with an undrape totostitate. included up mulbo!e tees to Jeffrey Epstein images-2jpg Bill Clinton links to Prince Andrew's billionaire friend Jeffrey ... Jeffrey Edward Epstein is an American financier and science and ve.vw.darymaitco.uk/.../Clinton-links-Andrews-bilionairaper... - Dal y Mail - education philanthropist. He worked at Bear Steams early in his career Mar 19, 2014 - Newly disclosed flight logs show that between 2002 and 2005 the former and subsequently formed his own firm. Wikipedia President travelled around the world courtesy of Jeffrey Epstein Born: January 20, 1953 (age 61), Coney Island, New York City, NY images -3.jpg e Education: Lafayette High School, Cooper Union Jeffrey Epstein - Huffington Post www.huffingtonpost.comrtag/Jeffrey-epsteln/ - Thanks to funding from a maverick New York science investor called Jeffrey Epstein. People also search for V ew 15. more virtual and robotic models of the human brain are moving away from ... P1 images -4.jpg Jeff Epstein I Bessemer Venture Partners vArWtivp.COrri h Team • Bessemer Venture Partners - Jeff Epstein is an Operating Partner at Bessemer Venture Partners. working out of the Ghislaine Prince Robert Les Wexner Martin Menlo Park. CA office. Maxwell Andrew. Maxwell Nowak Duke of Y.. te. 4 JEFFREY EPSTEIN VI FOUNDATION: Home COCii:s3Ck -4 Images-5.j pg v.wwieffreyepsteinfounciatson.comi - The Jeffrey Epstein VI Foundation funds university departments. individual scientists and experiments in a wide range of subjects. Jeffrey Epstein • I'd th s U 800 x 800 - images-6.j pg baby.steals.com EFTA01192381

EFTA00168246.pdf

DataSet-9 Unknown 63 pages

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. EFTA_00017791 EFTA00168247 itte ?,fiatea)7,0 477,10NE /n-3 1/57'- ?AA At 7 /F43 — c7414/ /9/,‘ //ohoceP ders-- a OW, 4 97260? / 1 c2oV7— dos-oz /1/447,evo e t3.0 r al 37 //et, / Rod O2(3f RIM 7/7 ao/a at,/ - gas, 071460 ,4\ RdR3 9 — RR Pv y 14/ 9\412 4tem_socor mlIMos3 /0909/6" / 0, 9-A4 /1,09.e.isete1.— — 71-6 EFTA_000 17792 EFTA00168248 一5「石mf俨肠/ /ILP'C -l 厂Ee&扭>D嚯1 屏庞r ≠刻c 'V722JE 及O/D g7bcTT I 纥f¢H/L -D6c5 3 厨廊/D 』 3厨阂[ EFTa I779S EFTA00168249 Shmitka Air, Inc. Flight Logs N722JE Serial 5 760750 S76C++ Larry Visoski cell, - . ./..s Date: 3 - .3 4-/ -11 To: 55' - FAy rom: 4'=-/Ay - 5s y / •• Trip # 3 Pilot:1 Co-Pilot: ' Airframe: 7 <4; a Landings: 1 E3 4:1 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