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1250 Broadway
Suite 2400 VERITEXT
National Deposition & LitigatIon Services 212-279-9424
New York, NY 1OX)1 fax 212-279-9643
BETTER IN EVERY CASE
June 24, 2011
Harry P. Susman, Esq.
Susman Godfrey L.L.P.
1000 Louisiana Street, Suite 5100
Houston, Texas 77002-5096
In the Matter of the Arbitration Between Fortress VRF I LLC, Claimants,
and Jaspers, Inc. Respondent
May 25, 2011 Deposition of Elise Hubsher
Dear Mr. Susman:
Z The deposition transcript has been reviewed by the witness.
ID No corrections/changes were made.
El Attached are the corrections/changes.
❑ Corrections were previously forwarded to counsel.
❑ The deposition transcript has not, as of this date, been read or signed by the deponent.
The 30-day period permitted by code for reading and signing has expired.
❑ The signature of the witness was waived.
❑ Other:
If you have any questions, please contact our office at (212) 279-9424.
Sincerely,
Z n o / -4;:re S
Shellia Edmonds
Client Services
Veritext, LLC
Enclosure
Cc: Allan J. Arffa, Esq. (Paul Weiss Rifkind Wharton & Garrison LLP)
William J. Schwartz, Esq. (Cooley Godward Kronish LLP)
EFTA00674738
Hubsher, Elise - 5/25/2011
Page 152
1
2 ERRATA SHEET
VERITEXT REPORTING COMPANY
3 1250 Broadway
New York, New York 10001
4 (212) 279-9424
5 CASE: Fortress v. Jeepers
DEPOSITION DATE: May 25, 2011
6 DEPONENT: Elise Hubsher
7 PAGE/LINE(S)/ CHANGE REASON
8
9
10
11
12
13
14
15
(A -c-eteLe
16
17
18
19
20
21
f(ii..47-keflaPto/i.
ELISE HUBSHER
22 SUBSCRIBE AND SWORN TO BEFORE ME
THIS &or^ DAY OF ciult-e , 2011.
23 • MARISOL SANCHEZ
• Notary Public - Slate of New York
24 NO. OISA6210787
Oualified in Richmond ou t
25 (NOT IC) MY C
IPMMIPSSION
3 EX ommission Expires it 3
Merrill Corporation - New York
1-800-325-3376 www.merrillcorp.com/law
EFTA00674739
HUBSHER ERRATA SHEET-EXHIBIT 1
f.CM iTu k- :" C1 ;1, I-11g- I ;14" QM.
10:7 "interest" should be "interested" Reporter Misheard
14:25 "You're" should be "You were" Reporter Misheard
23:20 "it weren't" should be "I wasn't" Reporter Misheard
28:7 "din" should be "Dan" Reporter Misheard
28:17 "situations" should be "conversations" Reporter Misheard
42:5 "are" should be "is" Reporter Misheard
66:5 "account" should be "accounting" Reporter Misheard
85:24 "win" should be "when" Typo
93:20 "he" should be "you" Reporter Misheard
103:20 "apply" should be "imply" Typo
111:3 "White's and you kind of a" should be Reporter Misheard
"White send a"
145:13 "mad" should be "had" Typo
145:15 "Exempt" should be "Except" Typo
EFTA00674740
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From:
To: Darren Indyke <
Subject: Fwd: Deposition Transcripts
Date: Thu, 17 Mar 2011 18:52:29 +0000
Attachments: Rodriguez,_Alfredo_-_Continued_Depo_8-07-09_(Doe_2).pdf
Inline-Images: bcic.gif
Begin forwarded message:
From: "David A. Yarema" >
Date: March 17, 2011 2:47:28 PM EDT
To: , <
Subject: Deposition Transcripts
Attached per your request is the deposition transcript of Alfredo Rodriguez (8/7/09). Juan Alessi's is not in the
deposition folder. However, I'm going to check a few other folders. I also may have a hard copy I can scan. Do not
hesitate to contact me if you have any questions. Thanks.
Dave
David A. Yarema - Attorney at Law
I www.bciclaw.com
This e-mail contains legally privileged and confidential information intended only for the individual or
entity named within the message. Should the intended recipient forward this message to another
person or party, that action could constitute a waiver of the attorney/client privilege. If the reader of
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EFTA00437054
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18 pages
NOTES OF QUOTES AND STATEMENTS FROM DEPOSITION TRANSCRIPTS
I. Deposition of L.M.
Although L.M. has sought in her civil case against Epstein to portray herself
as an innocent, who was damaged by her interactions with Epstein, both her
behavior and her own sworn statements during the course of her deposition in her
civil case belie her claims. Repeatedly throughout the course of her deposition, L.M.
engaged in the frequent use of profanity and personal attacks on Epstein's counsel.
For example, during her deposition, L.M. made the following comments:
A: You're an asshole.
Q: You were a -
A: You're a fucking asshole.
(see Depo Transcript 130:10-19)
A: You are just fucking sitting here making money.
(see Depo Transcript 132:9-10)
Q: Ok, you were partying, right?
A: Yeah, like normal people do like you're going to probably do after this
with all your fucking money.
(see Depo Transcript 133:3-5)
Q: ... Let's be honest
A: Okay. Lees be honest.
Q: Did you ever send?
A: Yeah Jackass. You're a fucking asshole.
(see Depo Transcript 225:19-23)
In fact, L.M.'s use of profanity was so egregious and disruptive during her
deposition that the court agreed to extend her deposition for six hours and ordered
her attorney to caution L.M. against engaging in such further inappropriate
behavior:
But the witness should be warned that the Court will not tolerate any further
vulgarities, any further accusations without merit relative to counsel, any
further attacks on counsel, any references to counsel's children or anything
of that nature.
I will allow the deposition ... without interruptions of the same type that we
witnessed by virtue of my reading of this transcript on several occasions
now, to last another six hours, total. Period.
1
EFTA01116345
I want to put on record that the vulgarities, the attacks on counsel, the
attacks of a personal nature that were communicated by L.M. were such that,
if they are repeated, that sanctions will be assessed, and those sanctions
could include the striking of the pleadings.
(see November 3, 2009 Hearing Transcript 9:20-10:23)
In addition to her "vulgar" behavior during her deposition, L.M. admitted
during the deposition that L.M. "started drinking, partying and having fun, when I
was around 15, I guess....14 going into 15" (see Depo Transcript 304:19-22). She
admitted under oath that "I lost my virginity when I was 14 years old." (see Depo
Transcript 109:17-18). She also admitted that she did "any drugs I could get, coke,
pain killers. I have done many drugs, ecstasy and -- ... and Xanax." (see Depo
Transcript 86:12-15) She testified that she started using drugs when "I was in
seventh and eight and ninth. Not when I was in seventh. More when I was in eighth
and ninth." (see Depo Transcript 86:22-24) She admitted, however, that Epstein
never provided L.M. with any drugs or alcohol:
Q: Jeffrey Epstein never gave you any drugs did he?
A: No.
Q: He was an antidrug person, wasn't he?
A: That's what he said.
Q: And he made that pretty clear to you?
A: Yes.
Q: Never gave you alcohol, right?
A: Never.
Q: Told you he didn't believe in alcohol. Didn't drink it himself, right?
A: True.
Q: Always treated you well when you were at his house, didn't he?
A: Of course.
(see Depo Transcript 305:5-306:1)
L.M. also testified under oath that she and her friend, E.W., worked as topless
dancers at a strip club when L.M. was only fourteen or fifteen years old:
Q: Okay, when you thought [E.W.] was 14, at what club was she dancing?
A: We both went to Club Cabaret.
...
A: When we were, when we were 14, we went there like once or twice.
...
Q: So, you went in there at age 14 with her? Were you 14 at the time?
A: Yes. She might have been 15. I was maybe just turned 15.
...
Q: What did you do [at Club Cabaret)?
A: I was an entertainer.
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EFTA01116346
Q: And then when you say you were entertainment, what did you do?
A: I was a dancer.
Q: Meaning you got up on stage, right?
A: Yes.
Q: Took your top off, right?
A: Yes.
Q: Did you do lap dances?
A: Not at this particular club.
Q: You have done them at other clubs?
A: Yes.
(see Depo Transcript 299:2-300:21)
L.M. also testified that she "probably" told Epstein that she worked at that strip club.
(see Depo Transcript 300:3-4)
L.M. also admitted that she was a call girl/escort since the age of 15. She
testified at her deposition: "Well, I lived life as a prostitute" (see Depo Transcript
156:7), "I am a prostitute when I make money" (see Depo Transcript 156:12-13),
and "I was a call girl and I worked for myself.... From the age of 15 to the age of 21"
(see Depo Transcript 280:16-19). In fact, L.M. admitted to making $1,000 a day or
more from prostitution on "maybe" more than 20 occasions in one year alone:
Q: You earlier said that in the year 2008, some days you made a
thousand dollars a day, some days you made $2,000 a day. How many days
out of the year would you say you made a thousand dollars a day or more a
day in the year 2008?
A: I don't know.
...
Q: Was it more than ten?
A: Maybe.
Q: Was it more than 20?
A: Maybe.
(see Depo Transcript 157:11-159:6).
L.M. also admitted under oath to keeping a list of amounts she collected from her
johns in "two or three" lined books that she kept for the years "06, 07, 08 and 09"
(see Depo Transcript 59:13-64:12), including a book of "Psalms" that she obtained
from a religious store (see Depo Transcript 152:1-14).
L.M. attempted to lay blame on Epstein during her deposition for, among
other things, her life as a prostitute. (see Depo Transcript 129:5-23). Yet L.M.
admitted that she never had sexual intercourse with Epstein and never touched
Epstein's penis:
Q: You never had sexual intercourse with Mr. Epstein, did you?
3
EFTA01116347
A: Penis inserted into the vagina, no.
Q: Did he ever insert his penis into your mouth?
A: No.
Q: Did he ever insert his penis into your anus?
A: No.
Q: Did he ever insert his penis into your vagina?
A: No.
...
Q: Did you ever hold his penis in your hand?
A: No.
(see Depo Transcript 71:15-72:9)
Moreover, sworn deposition testimony froi, the person who first
brought L.M. to Epstein's home, indicates that L.M. engaged in prostitution before
L.M. ever met Epstein. In her deposition, Ms. Adriano testified that on L.M.'s second
visit to Epstein's home, L.M. quoted to Epstein prices for various sexual favors that
L.M. and L.M.'s mother performed. Ms. Adriano testified that L.M. was "telling
[Epstein] about some stuff that her mom and her did sexually for money or some
stuff like that" (see Depo Transcript of C.M.A. 280:9-11) and that L.M. was "offering
information" to Epstein:
A: That her and her mom have had, her mom does things and has prices
for things. Something of that matter...
Q: Sexual nature?
A: Yeah.
(see Depo Transcript of C.M.A. 276:16-277:11)
II. Deposition o (C.M.A.)
Another woman claiming in her civil case to have lost her innocence to
Epstein Yet, Ms. Adriano's sworn deposition testimony in her
civil case against Epstein paints quite a different picture. Ms. Adriano, who during
her deposition appeared at times disoriented and even once fell asleep, testified
under oath to a pervasive history of illegal drug abuse. For example:
Q: You have used a number of illegal drugs in the past, have you not?
A: Yes, I have.
Q: And what drugs have you used in the past?
A: Cocaine, marijuana, pain pills, Morning Glories, Angle Trumpets, acid,
Ecstasy.
Q: Heroin?
A: Yep, I've tried heroin.
Q: You have tried crystal meth?
4
EFTA01116348
A: Yeah...
(see Depo Transcript 87:11-88:8).
Ms. Adriano admitted that she began smoking marijuana before she ever met
Epstein (see Depo Transcript 274:11-13). In addition, she testified:
Q: And you started using marijuana at age what?
A: Thirteen.
Q: And you used it with what degree of frequency?
A: I don't know, every day.
(see Depo Transcript 274:14-19)
She further admitted that she altered Roxicodone pills to take the drug
intravenously because "it wasn't working for me swallowing it anymore" and
because "it hits you faster" (see Depo Transcript 97:14-20). She also testified that "1
told [Wellington Regional Hospital] I was an IV drug user." (see Depo Transcript
271:20-23).
Like, L.M., Ms. Adriano confirmed under oath that Epstein never gave or even
offered her drugs or alcohol:
Q; Mr. Epstein never gave you any drugs, did he?
A: No.
(see Depo Transcript 103:8-10)
Q: He never told you to use drugs in his house, did he?
A: No, he never told me to.
Q: He never gave you alcohol in his house, did he?
A: No.
(see Depo Transcript 106:7-12)
Q: He never attempted to drug you in any manner, did he?
A: No.
Q: Never even offered you drugs, correct?
A: Correct.
(see Depo Transcript 131:13-17)
In addition to her pervasive history of drug abuse, Ms. Adriano also admitted
in her deposition that she had a long history of sexual activity since the age of 12,
well before she ever met Epstein:
Q: So, by, by your acknowledgement in these answers to interrogatories
before you ever went to Mr. Epstein's house the first time, you had had sexual
relations with Josh Moles, Danny Andre Brian and somebody
whose last name you can't remember, an
A: And that's it.
5
EFTA01116349
Q: And Michael Riccoca?
A: No.
Q: Not Michael Riccoca, but up throng
A: Yes.
(see Depo Transcript 258:6-16)
Q: Okay. And when was the first time that you had a sexual experience
with another woman?
A: When I was 12.
Q: and who was this other woman?
A: My ex-girlfriend.
(see Depo Transcript 161:18-22)
Ms. Adriano and one of her boyfriends even filmed themselves having sexual
intercourse when Ms. Adriano was just 13 years old:
Q: ... When were you filmed in the nude?
A: With one of my boyfriends.
•••
Q: And when was he your boyfriend?
A: I was 13.
Q: Excuse me?
A: When I was 13.
Q: Was this before or after the point in time that you had your
relationship with Jennifer?
A: It was after. Well, it was before. I don't - It was like during type of
thing. Even though she was my girlfriend, we still had boyfriends if that
helps you.
Q: But the film was of the two of you together as supposed [sic] to just
you alone?
A: Yes.
Q: And what were you and he doing in the film?
A: Having sex.
Q: Just intercourse?
A: Yeah.
(see Depo Transcript 200:25-202:5)
Ms. Adriano testified that her first child was born "when I was 17." (see Depo
Transcript 204:10-11). She testified to having a sexual relationship with the father
of that child since she was 13 years old:
Q: When did you first meet Mr. Haught?
A: When I was 13.
Q: Did you, did you meet him before you first went to Mr. Epstein's?
6
EFTA01116350
A: Yes.
Q: Had you had a sexual relationship with Mr. Haught, obviously?
A: Yes.
Q: Had you had sex with Mr. Haught before you went to Mr. Epstein's for
the first time?
A: Yes.
Q: And what sexual acts had you engaged in with Mr. Haught before you
went to Mr. Epstein's?
A: Intercourse.
Q: And did you consider Mr. Haught to be your boyfriend?
A: Yeah.
Q: And you were dating him during the entire period of time that you
went to Mr. Epstein's
A: Yeah.
Q: And did Mr. Haught ever physically bring you to Mr. Epstein's house?
A: Yes.
Q: ... Ever any occasion when Mr. Haught brought any females that he
dropped off at Mr. Epstein's other than -
A: Yes, me and A.L. and me and L.M.
(see Depo Transcript 207:20-209:17)
Ms. Adriano testified about having a frighteningly violent and tumultuous
history with this boyfriend. For example:
A: He cheated on me with A.L. and I suppose he felt guilty about it. So, he
tried to say I was cheating on him and I wasn't cheating on him. He was
cheating on me and he felt guilty, and then decided he was going to try to kill
me.
Q: And you were afraid - where were you when this gun was held to
your head?
A: In the middle of a field.
(see Depo Transcript 258:22-259:4)
Q: For approximately how long did the event take place that= held
a gun to your head?
A: Like five minutes and then we kissed and made up and had sex.
Q: In the field?
A: Yep.
(see Depo Transcript 260:24-261:4)
Q: Was there another occasion th was physically violent
towards you?
A: Yes.
Q: When was that?
A: When he tried to drown me in a canal.
7
EFTA01116351
(see Depo Transcript 261:15-19)
Epstein even counseled Ms. Adriano against continuing her relationship with this
violent man, but Ms. Adriano ignored Epstein's advice:
Q: And when did you tell Mr. Epstein about it?
A: On one of the occasions I went to his house.
Q: And what did he say?
A: I don't know. He talked to me about it.
Q: Was he sympathetic toward you?
A: A little bit.
Q: Did he tell you you ought to get away from this guy?
A: Yeah.
Q: Did you pay attention to what he said?
A: Obviously not, if I had a kid with him some years later.
(see Depo Transcript 262:5-17)
Despite Ms. Adriano's established history of drug abuse originating prior to her
meeting Epstein and long history of sexual activity with members of both the same
and opposite sexes that predated her interactions with Epstein, Ms. Adriano claims
injury by Epstein in her civil case. She makes these claims even though she made
the following admissions in her deposition:
Q: Did you ever have sexual intercourse with Mr. Epstein?
A: No.
(see Depo Transcript 106:13-15)
Q: Did you ever touch Mr. Epstein's penis -
A: No.
Q: -- in any way?
A: No, no.
(see Depo Transcript 109:1-4)
Q: All right. Would you, would you say that during the period from May
'02 to August '03 Mr. Epstein was good to you?
A: Yes.
(see Depo Transcript 127:23-128:1)
Q: Did he ever, did he ever strike you ever, hit you?
A: No.
Q: Did he ever commit an act of domestic violence against you?
A: No.
(see Depo Transcript 129:2-10)
Q: ... Did Mr. Epstein ever threaten you in any manner?
8
EFTA01116352
A: No.
(see Depo Transcript 131:2-4)
In fact, Ms. Adriano testified that she enjoyed going to Epstein's home:
Q: Did you enjoy the occasions when you went to Mr. Epstein's?
A: Yes. Like enjoyed collecting the money, yes.
Q: Well, you enjoyed what you were doing, didn't you? You enjoyed
spending time with him?
A: Not exactly spending time with him. I enjoyed going to be able to
collect that much money.
(see Depo Transcript 141:10-16)
Ms. Adriano enjoyed collecting the money so much that she, herself, initiated contact
in order to schedule visits to collect that money:
Q: Well, there were also occasions when no one from Mr. Epstein called,
but rather you called Mr. Epstein's and asked to go?
A: Yes.
Q: And that was because you wanted to go and earn some money,
correct?
A: Yes.
(see Depo Transcript 137:7-13)
Nevertheless, C.M.A. claimed in her deposition that specifically because of her
interactions with Epstein:
A: I have a very hard time working around older men or in specific
situations.
Q: What situations would those be?
A: I don't trust anybody and I don't feel safe in some places.
Q: Well, you say you don't trust anybody?
A: Well, I don't trust men.
Q: What—any kind of particular kind of men or just -
A: Older men.
Q: And what's your definition of "older"?
A: Above 40.
(See Depo Transcript 66:10-21)
Yet, despite her claimed "trust" issues with men over 40 years old, Ms. Adriano
admitted under oath at her deposition that, after she stopped seeing Epstein:
A: I was working for an escort service.
Q: And what was the name of that escort service?
A: Think Pink and Palm Beach Escorts.
Q: That would be two separate escort services?
9
EFTA01116353
A: Yes.
(see Depo Transcript 68:12-18)
Q: And thereafter, after you were employed, did you on numerous
occasions go out with men over 40 years of age?
A: Yes.
(See Depo Transcript 75:21-24).
Incredulously, Ms. Adriano claimed in her deposition that on the occasions when she
went out with people that were over 40 years old, she would only go "to dinner or
to go out dancing" or "to a movie or to like an event that they had to go" (see Depo
Transcript 83:11-16), that she told the escort services that "I would not do anything
sexual with anybody" (see Depo Transcript 75:18-19), and that if somebody tried to
do something sexual with her, then "I left" (see Depo Transcript 84:5-10). Though
she claimed that nothing sexual happened with her clients, according to her
testimony, somehow:
Q: ... you have made as much as a thousand dollars a night -
A: Yes.
Q: -- going out with people, men that are over 40, have you not?
A: Yes, that's true.
(see Depo Transcript 67:15-20)
and
Q: Is it true that the amount of money that you earned with Think Pink
and with Palm Beach escorts was the most you ever earned as a wage in your
life?
A: Yeah.
(see Depo Transcript 82:12-16)
III. Deposition o V.Z.):
Although V.Z. also claimed in her civil case injury from her interactions with
Epstein, her sworn deposition testimony clearly establishes that any injuries that
she may have sustained were the result of a dangerous and violent relationship that
she carried on with another man during the entire period that she claims to have
been interacting with Epstein:
Q: Now, read to the ladies and gentlemen of the jury what you wrote
occurred on Setpember 20th, 2004 with Mr. Vinyard.
A: Preston and I were laying in bed. When a guy friend called my cell
phone, Preston said that I was a slut, whore, cunt that was cheating on, that I
was cheating on him. Preston started checking, checking, I don't even -
Q: Choking?
10
EFTA01116354
A: -- yeah, choking me into the mattress, and then when I went into my
purse, he threw me against the wall and started yelling at me. Then Preston
pushed me out the door. And whenever I asked for the rest of my belongings,
he told me to wait.
Whenever he came back, he spilled a bear all over and threw
cigarettes it in my face and slammed me into the ground. I got up. I went to
my car and he followed me.
A: Shut my door and he opened it. He spit in my face and he continued to
call me a whore, a slut, and cunt. I shut the door, and he opened it again, and
he got in my face, grabbed my arms very hard[.] [T]o make him let go[,] I bit
his arm. I bit his arm and he bit me back on my finger and cut it open. He
was, he was biting so hard that he was repeating - he repeatedly harassed
me since last night ...
Q: Would you treat a dog like this?
A: No.
Q: No human being ought to be treated like this, should they?
A: No.
(see Depo Transcript 357:6-360:4)
V.Z. admitted under oath that V.Z. was engaged in a sexual relationship with this
abusive man since the age of 16 (though her admissions during the deposition
indicate that it was earlier than that):
Q: Now, it's a fact, is it not, that by the beginning of your junior year, by
the beginning of let's say, August of '03, you were having sexual relations
with a Preston Vinyard, weren't you?
A: Yeah.
(see Depo Transcript 180:7-11)
Q: Okay. So, Mr. Vinyard had taken his penis and inserted it in your
vagina before your junior rear of high school; isn't that right?
A: Yeah, I think so, yeah.
Q: Had you given him oral sex before your -
A: Yeah.
Q: -- junior year of high school?
(see Depo Transcript 181:21-182:2)
Q: Are you - did you - are you claiming you lost your virginity to Preston
Vinyard?
A: Yeah.
(see Depo Transcript 183:19-21).
V.Z. testified that when she began this sexual relationship with this abusive man, he
was then a 23 year-old adult, 7 years older than she, had been in prison and was an
alcoholic:
11
EFTA01116355
Q: When was the first time you went over to his house?
A: When I was 16.
Q: Sixteen. Okay. He's 23 and your 16 when you first started dating him,
right?
A: Yes, somewhere in that time - I'm pretty sure it's somewhere in that
time frame.
(see Depo Transcript 198:3-11)
A: Well, when I first started dating him, he [my father] didn't really know
that - how old Preston was. He didn't know that he had a criminal
background until later on -
(see Depo Transcript 199:17-21)
A: There was a time, where he, he would drink a lot. He was an alcoholic
and he would get out of control when he drank...
(see Depo Transcript 28:11-29:23)
Because of Mr. Vinyard's severe violence and abuse against her, V.Z. obtained a
restraining order against him during her junior or senior year of high school:
Q: Did you say you got a restraining order against him?
A: Yeah.
Q: And what year of high school were you in when you got the
restraining order against the first love of your life, Mr. Vinyard, who you now
say is abusive to you?
A: I think it was my junior or senior year.
(see Depo Transcript 202:10-22)
Nevertheless, both before and after she obtained this restraining order, V.Z.
continued to maintain a sordid and damaging sexual relationship with Mr. Vinyard.
For example, V.Z. admitted under oath that she made a homemade video of her
sexual exploits with Mr. Vinyard from her bedroom in her parents' house using her
parents video equipment while V.Z. was in high school:
A: I have made a homemade video before.
...
Q: ... what did this homemade video depict?
A: Me and my boyfriend.
Q: At the beach or -
A: -- making out together.
Q: -- having sex?
A: Yeah.
Q: Having sexual intercourse?
12
EFTA01116356
A: Yeah.
(see Depo Transcript 226:11-227:7)
Q: When you made the videotape of you and Preston having sexual
relations, what acts were recorded on the videotape?
A: On the tape?
Q: Yeah, the tape -
A: Sex.
...
Q: You used your parents' video camera -
A: Yeah.
Q: -- to record you and this fellow, Preston Vinyard, engaged in sexual
relations?
A: Yeah.
Q: Where did the actual filming take place?
A: In my, my house.
Q: What house?
A: My room.
Q: The room, the house your parents owned?
A: Yeah.
Q: Tell the ladies and gentlemen, look in the camera and tell the ladies
and gentlemen of the jury you don't know if you were in high school when
you made this tape.
A: I was in high school when I made this with Preston.
Q: So, tell me what specific acts you engaged in with Mr. Vinyard that you
then recorded on this video, to your parents' videotape machine in your
parents' home.
...
A: Of us having sex.
Q: I want to know the specific acts. Did it reflect oral sex?
A: Sure.
Q: Were you, did it reflect you having Preston Vinyard's penis in your
mouth?
A: Yeah.
Q: Did it - show him licking your vagina?
A: Yeah.
Q: Did it - did he insert his penis in your vagina on this tape?
A: Yeah.
(see Depo Transcript 361:20-368:8)
13
EFTA01116357
V.Z. also testified that she caught herpes from Mr. Vinyard when she was 15 or 16
years old:
Q: Where did you get the herpes from?
A: The one person I was sleeping with.
Q: Well, who is that?
A: Preston.
Q: Do you remember when you got the herpes?
A: Yeah.
Q: Still in high school at the time?
A: Yeah.
(see Depo Transcript 324:24-325:10)
Q: How old were you at that time?
A: No, I don't remember?
Q: Fifteen?
A: I don't remember.
Q: Well that was before you got pregnant, right?
A: Yeah could have been like when I was 16.
Q: Okay. So 15 or 16?
A: One of those two.
(see Depo Transcript 326:23-327:9)
V.Z. admitted to having three abortions when she was with Preston Vinyard, two of
which occurred while she was in high school and two of which occurred after she
obtained the restraining order against Mr. Vinyard:
Q: How many abortions have you had?
A: Three.
(see Depo Transcript 299:16-21)
Q: All right. When did you have your first abortion?
A: Sixteen.
Q: Which would have been - what year was that?
A: It might have been my sophomore or junior year. I don't remember.
Q: Sophomore or junior year in high school?
A: Yeah.
(see Depo Transcript 311:7-21)
Q: When was your second abortion?
A: In my senior year in high school.
Q: That was when you were 17?
14
EFTA01116358
A: Yes.
(see Depo Transcript 312:23-313:1)
Q: So, after you got an injunction against domestic violence, you hooked
up with Preston Vinyard again and got pregnant with him again, and had
another abortion with him; is that right?
Q: Is that right?
A: Yeah.
(see Depo Transcript 426:9-16)
V.Z. admitted that she began drinking alcohol before she was even 16 years old and
that during her relationship with Preston Vinyard, she was drunk with him twice a
week:
Q: And do you recall when you first started drinking?
A: No. I don't remember the first time I started drinking, but - no, I
don't.
Q: Was it before you were 16?
A: Maybe, yeah.
Q: And how many times were you drunk with old Preston?
A: I don't even know that answer. I don't know.
Q: Well, Preston testified yesterday that you were drunk about twice a
week with him. Would you agree with that estimate from him?
A: Yeah, probably.
(see Depo Transcript 213:11-25)
V.Z. was even arrested for DUI when she was 17 years old:
Q: Okay. And it was - it was when you were 17, between the ages of 17
and 18?
A: Uh-huh.
Q: And what were you arrested for?
A: DUI
(see Depo Transcript 25:17-26:1)
V.Z. also admitted that before and during the course of her relationship with Mr.
Vinyard, V.Z. used illegal drugs, including marijuana, cocaine and ecstasy:
Q: You had smoked pot before you met Mr. Epstein, had you not?
A: Yeah.
(see Depo Transcript 221:3-5)
Q: I want to ask you again, did you ever do any drug with Mr. Vinyard
that you didn't have any prescription for?
15
EFTA01116359
A: Yeah.
Q: What drugs?
A: Coke.
(see Depo Transcript 214:24-215:4)
Q: Any pills that you have taken before that you didn't have a
prescription for?
A: Yeah, I have tried ecstasy.
(see Depo Transcript 217:4-6)
Q: For what period of time did you take ecstasy?
A: I didn't It's not like I took it every day. It's not like I took it every day.
On occasion, I tried it.
(see Depo Transcript 217:19-23)
V.Z. has attempted to blame Epstein for any injuries she claims to have sustained
during the period that she was engaged in this unfortunate and abusive relationship
with Preston Vinyard. " though V.Z. admitted in her deposition that she
was specifically told b "Don't tell [Epstein) your age" (see Depo
Transcript 62:17-22). Moreover, V.Z. testified:
Q: Didn't have any sexual relations with Mr. Epstein did you?
A: No.
(see Depo Transcript 180:12-14)
Q: And by the way, did you - did you ever touch Mr. Epstein's penis?
A: No.
(see Depo Transcript 361:5-7)
Q: Did he ever physically hurt you in any manner whatsoever?
A: No.
Q: Did he ever demean you in any manner whatsoever?
A: No.
(see Depo Transcript 169:16-25)
Q: Mr. Epstein never gave you drugs, correct?
A: No.
(see Depo Transcript 221:12-14)
And V.Z. admitted during her deposition:
Q: Was Mr. Epstein good to you?
A: Yeah.
(see Depo Transcript 122:9-10)
16
EFTA01116360
Q: And Mr. Epstein, as you said before lunch, was very nice towards you,
was he not?
A: Yeah.
A: He was really nice, like friendly.
(see Depo Transcript 168:9-20)
In fact, V.Z. admitted that from the period of time after she was of legal age and
legally deemed able to make her own decisions regarding her interactions with
Epstein, she voluntarily saw Epstein as much as 50 times:
Q: Can you tell me how many times you went to Mr. Epstein's between
June 1st of 2005 and Octoer 31st of 2005?
A: Well, approximately, approximately like 30 to 50 times.
Q: Okay. You went voluntarily. Nobody forced you to go to Mr. Epstein's,
correct?
A: Yeah.
(see Depo Transcript 77:17-79:4)
Moreover, V.Z. admitted under oath that when V.Z. first learned of the claims against
Epstein and before she filed her law suit against Epstein, V.Z. "was like AnfnnAing
Mr. Epstein" (see Depo Transcript 276:2), and that V.Z. and her friend
liscussed and told others that such claims were outrageous:
Q: Did you ever, at any point in your life right up until today tell anyone
that you thought it was outrageous that anyone would file a lawsuit against
Jeffrey Epstein because everybody knew what the deal was and knew what
they were doing or words to that effect?
A: Yeah, I said that to Lauren, because I didn't even think I was doing
anything wrong at the time...
A: We, she said we both said to each other. We were just, like, I can't
believe this is happening, like Jeffrey is such a great guy, like, you know, like,
saying all this stuff about, about him...
(see Depo Transcript 275:18-277:2)
Q: All right. • ' ' at you have made this statement to
people other th etween January of '06 and January of '09,
that everybody that went to see Jeffrey Epstein knew exactly what they were
getting into, did it voluntarily, and it's outrageous that they would sue him?
A: Yeah.
17
EFTA01116361
Q: Now, I want to tell you that you filed your lawsuit in 2008. Okay. You
can assume and I'm sure your counsel will correct me if I'm wrong, but you
didn't file this lawsuit until 2008. You had a lot of conversations with your
friends that had gone to Jeffrey Epstein before you filed this lawsuit, didn't
you?
A: Yeah.
Q: And all those conversations were that everybody knew what they
were getting into, and it was all done voluntarily, and at that time you-all
thought it was crazy that anybody would sue Jeffrey Epstein, didn't you?
A: Yeah.
(see Depo Transcript 282:8-25)
Finally, V.Z. also admitted that even after the police contacted her when she was in
college and of legal age, but before she had retained legal counsel in her civil case,
she "probably more than likely" would have continued to see Epstein. See Depo
Transcript 393:10-16.
V.Z.'s claims against Epstein defy credibility. She was consistently evasive
during her deposition. She admitted in her deposition to lying under oath and to
lying in evaluation interviews with her own experts, including about such things as
her drug usage (see Depo Transcript 402:22-403:2) and her three aborted
pregnancies (see Depo Transcript 405:2-406:9). Most tellingly, V.Z. admitted:
Q: So, we don't really know, even when you're under oath, whether
you're telling the truth or you're lying, do we?
A: No.
(see Deposition Transcript 401:7-10)
In light of her admitted violent and sordid history with Mr. Vinyard during
the entire period that she claims to have been interacting with Epstein, her evasive
responses to direct deposition questions, her admitted deceptions to her own
experts, her revelation that her testimony cannot be relied upon, even under oath,
her admissions regarding her positive personal feelings about Mr. Epstein and her
pre-litigation characterization of the civil claims against Epstein as outrageous, V.Z.'s
civil claims of injury by Epstein do not withstand scrutiny.
18
EFTA01116362
DataSet-10
Unknown
3 pages
125O Broadway
Suite 2400 VERITEXT
National Deposition & LitigatIon Services
New York, NY 1OX)1 fax
BETTER IN EVERY CASE
June 24, 2011
Harry P. Susman, Esq.
Susman Godfrey L.L.P.
1000 Louisiana Street, Suite 5100
Houston, Texas 77002-5096
In the Matter of the Arbitration Between Fortress VRF I LLC, Claimants,
and Jaspers, Inc. Respondent
May 25, 2011 Deposition of Elise Hubsher
Dear Mr. Susman:
Z The deposition transcript has been reviewed by the witness.
❑ No corrections/changes were made.
EI Attached are the corrections/changes.
❑ Corrections were previously forwarded to counsel.
❑ The deposition transcript has not, as of this date, been read or signed by the deponent.
The 30-day period permitted by code for reading and signing has expired.
❑ The signature of the witness was waived.
❑ Other:
If you have any questions, please contact our office at
Sincerely,
1 --;?-7 / -4;:re S
Shellia Edmonds
Client Services
Veritext, LLC
Enclosure
Cc: Allan J. Arffa, Esq. (Paul Weiss Rifkind Wharton & Garrison LLP)
William J. Schwartz, Esq. (Cooley Godward Kronish LLP)
EFTA00607681
Hubsher, Elise - 5/25/2011
Page 152
1
2 ERRATA SHEET
VERITEXT REPORTING COMPANY
3 1250 Broadway
New Y 001
4
SSW
5 CASE: Fortress v. Jeepers
DEPOSITION DATE: May 25, 2011
6 DEPONENT: Elise Hubsher
7 PAGE/LINE(S)/ CHANGE REASON
8
9
10
11
12
13
14
15
(A -c-eteLe
16
17
18
19
20
21
f(ii..47-keflaPto/i.
ELISE HUBSHER
22 SUBSCRIBER AND SWORN TO BEFORE ME
THIS &or^ DAY OF ciult-e , 2011.
23 • MARISOL SANCHEZ
• Notary Public - Slate of New York
24 NO. OISA6210787
Oualified in Richmond ou t
25 (NOT IC) MY C
IPMMIPSSION
3 EX ommission Expires it 3
Merrill Corporation - New York
1-800-325-3376 www.merrillcorp.com/law
EFTA00607682
HUBSHER ERRATA SHEET-EXHIBIT 1
f.CM iTu k- :" C1 ;1, I-11g- I ;14" QM.
10:7 "interest" should be "interested" Reporter Misheard
14:25 "You're" should be "You were" Reporter Misheard
23:20 "it weren't" should be "I wasn't" Reporter Misheard
28:7 "din" should be "Dan" Reporter Misheard
28:17 "situations" should be "conversations" Reporter Misheard
42:5 "are" should be "is" Reporter Misheard
66:5 "account" should be "accounting" Reporter Misheard
85:24 "win" should be "when" Typo
93:20 "he" should be "you" Reporter Misheard
103:20 "apply" should be "imply" Typo
111:3 "White's and you kind of a" should be Reporter Misheard
"White send a"
145:13 "mad" should be "had" Typo
145:15 "Exempt" should be "Except" Typo
EFTA00607683
DataSet-10
Unknown
19 pages
NOTES OF QUOTES AND STATEMENTS FROM DEPOSITION TRANSCRIPTS
I. Deposition of.
Althougi has sought in her civil case against Epstein to portray herself
as an innocent, who was damaged by her interactions with Epstein, both her
behavior and her own sworn statements during the course of her deposition in her
civil case belie her claims. Repeatedly throughout the course of her deposition=
engaged in the frequent use of profani and personal attacks on Epstein's counsel.
For example, during her deposition made the following comments:
A: You're an asshole.
Q: You were a -
A: You're a fucking asshole.
(see Depo Transcript 130:10-19)
A: You are just fucking sitting here making money.
(see Depo Transcript 132:9-10)
Q: Ok, you were partying, right?
A: Yeah, like normal people do like you're going to probably do after this
with all your fucking money.
(see Depo Transcript 133:3-5)
Q: ... Let's be honest.
A: Okay. Let's be honest.
Q: Did you ever send?
A: Yeah jackass. You're a fucking asshole.
(see Depo Transcript 225:19-23)
In fact, use of profanity was so egregious and disruptive during her
deposition that the court agreed to extend her deposition for six hours and ordered
her attorney to caution against engaging in such further inappropriate behavior:
But the witness should be warned that the Court will not tolerate any further
vulgarities, any further accusations without merit relative to counsel, any
further attacks on counsel, any references to counsel's children or anything
of that nature.
I will allow the deposition ... without interruptions of the same type that
we witnessed by virtue of my reading of this transcript on several occasions
now, to last another six hours, total. Period.
EFTA_R1_00018824
EFTA01735431
I want to put on record that the vulgarities, the attacks on counsel, the
attacks of a personal nature that were communicated b} vere such that,
if they are repeated, that sanctions will be assessed, and those sanctions
could include the striking of the pleadings.
(see November 3. 2009 Hearing Transcript 9:20-10:23)
In addition to her "vul ar" behavior durin her de • osition admitted
durin the de • osition that
-22). She
admitted under oath tha see De • o
Transcri t 109.17-18 She also admitted that she di
see De o
Transcript 86:12-15) She testified that she started
(see Depo Transcript 86:22-24) She admitted, however, that Epstein
never provide' with any drugs or alcohol:
Q: Jeffrey Epstein never gave you any drugs did he?
A: No.
Q: He was an antidrug person, wasn't he?
A: That's what he said.
Q: And he made that pretty clear to you?
A: Yes.
Q: Never gave you alcohol, right?
A: Never.
Q: Told you he didn't believe in alcohol. Didn't drink it himself, right?
A: True.
Q: Always treated you well when you were at his house, didn't he?
A: Of course.
(see Depo Transcript 305:5-306:1)
also testified under oath that she and her friend
Q: Okay, when you though at what
A: We both went to
•••
A: When we were, when we were.we went there like once or twice.
•••
Q: So, you went in there at agenvith her? Were youE t the time?
A: Yes. She might have been I was maybe just turned
EFTA_R1_00018825
EFTA01735432
Q: What did you do
A: I was an
•••
Q: And then when you say you were what did you do?
A:
Q:
A: Yes.
Q:
A: Yes.
Q: Did you do
A:
Q:
A: Yes.
(see Depo Transcript 299:2-300:21)
also testified that she "probably" told Epstein that she worked at that
(see Depo Transcript 300:3-4)
also admitted that she was She
testified at her de osition (see Depo Transcript
156:7), see De o Transcri t 156:12-13 ,
and "I was a
(see Depo Transcript 280:16-19). In fact
more from
Q: Was it more than ten?
A: Maybe.
Q: Was it more than 20?
A: Maybe.
(see Depo Transcript 157:11-159:6).
also admitted under oath t
(see Depo Transcript 59:13-64:12), including a book of hat she obtained
from a -tore (see Depo Transcript 152:1-14).
EFTA_R1_00018826
EFTA01735433
II
other ngs
ttempted to lay_
blame on Epstein during her deposition for, among
(see Depo Transcript 129:5-23). Yet=
admitted that she never had sexual intercourse with Epstein and never touched
Epstein's penis:
Q: You never had sexual intercourse with Mr. Epstein, did you?
A: Penis inserted into the vagina, no.
Q: Did he ever insert his penis into your mouth?
A: No.
Q: Did he ever insert his penis into your anus?
A: No.
Q: Did he ever insert his penis into your vagina?
A: No.
Q: Did you ever hold his penis in your hand?
A: No.
(see Depo Transcript 71:15-72:9)
Moreover, sworn deposition testimony from the person who first
broughtetto Epstein's home, indicates tha before
■ ever me Epstein. In her de osition testified that on second
visit to Epstein's home,
that an was "telling
[Epstein] about some stuff tha i or some
stuff like that" (see Depo Transcript of C.M.A. 280:9-11) and that as "offering
information" to Epstein:
A:
• f that matter...
Q:
A: Yeah.
(see Depo Transcript of C.M.A. 276:16-277:11)
II. Deposition of
Another woman claiming in her civil case to have lost her innocence to
Epstein is Yeta sworn deposition testimony in her
civil case against Epstein paints quite a different picture. who during
her deposition a eared at time testified
under oath to For examp e:
EFTA_R1_00018827
EFTA01735434
Q:
A: es, ave
Q:
A:
Q:
A:
Q:
A: Yeah...
(see Depo Transcript 87:11-88:8).
admitted that she begs before she ever met
Epstein (see Depo Transcript 274:11-13). In addition, she testified:
Q:
A:
Q:
A:
(see Depo Transcript 274:14-19)
She further admitted that she
a so tests e that "I
tol see Depo Transcript
271
Like- confirmed under oath that Epstein never gave or even
offered her drugs or alcohol:
Q; Mr. Epstein never gave you any drugs, did he?
A: No.
(see Depo Transcript 103:8-10)
Q: He never told you to use drugs in his house, did he?
A: No, he never told me to.
Q: He never gave you alcohol in his house, did he?
A: No.
(see Depo Transcript 106:7-12)
Q: He never attempted to drug you in any manner, did he?
A: No.
EFTA_R1_00018828
EFTA01735435
Q: Never even offered you drugs, correct?
A: Correct
(see Depo Transcript 131:13-17)
In addition to he
in her deposition that she had
well before she ever met Epstein:
Q: So, by, by your acknowledgement in these answers to interrogatories
r- v rw n • Mr. E stein's house the first tim
an
A: And that's it
Q: And
A: No.
No
Q:
A: Yes.
(see Depo Transcript 258:6-16)
Q: Okay. And when was the
A:
Q:
A:
(see Depo Transcript 161:18-22)
Q:
A:
•••
Q:
A:
Q:
A:
Q: Was this before or after the point in time that you had your
A: It was after. Well, it was before. I don't - It was like durin e of
thin .
EFTA_R1_00018829
EFTA01735436
: res.
Q:
A:
Q:
A:
(see Depo Transcript 200:25-202:5)
testified tha (see Depo
Transcri t 204:10-11 .
Q: When did you first meet
A: When I was
Q: Did you efore you first went to Mr. Epstein's?
A: Yes.
Q:
A: Yes.
Q:
A: Yes.
A:
Q: And did you consider
A:
Q: during the entire period of time that you
went to Mr. Epstein's
A: Yeah.
Q: And ever physically bring you to Mr. Epstein's house?
A: Yes.
Q: . . . Ever any occasion whet brought any females that he
dropped off at Mr. Epstein's other t tan -
A: Yes, me an' and me and
(see Depo Transcript 207:20-209:17)
about having a
For example:
A:
EFTA_R1_00018830
EFTA01735437
A:
(see Depo Transcript 258:22-259:4)
: For a roximately how long did the event take place that
A:
Q:
A:
(see Depo Transcript 260:24-261:4)
Q: Was there another occasion that tanta
A: Yes.
Q:
A:
(see Depo Transcript 261:15-19)
Q: And when did you tell Mr. Epstein about it?
A: On one of the occasions I went to his house.
Q: And what did he say?
A: I don't know. He talked to me about it.
Q: Was he sympathetic toward you?
A: 4 "
Q:
A:
Q:
A:
(see Depo Transcript 262:5-17)
Despit
meeting pstein an
hat predated her interactions with Epstein laims
injury by Epstein in her civil case. She makes these claims even though she made
the following admissions in her deposition:
Q: Did you ever have sexual intercourse with Mr. Epstein?
EFTA_R1_00018831
EFTA01735438
A: No.
(see Depo Transcript 106:13-15)
Q: Did you ever touch Mr. Epstein's penis -
A: No.
Q: -- in any way?
A: No, no.
(see Depo Transcript 109:1-4)
Q: All right. Would you, would you say that during the period from
r. Epstein was good to you?
A: Yes.
(see Depo Transcript 127:23-128:1)
Q: Did he ever, did he ever strike you ever, hit you?
A: No.
Q: Did he ever commit an act of domestic violence against you?
A: No.
(see Depo Transcript 129:2.10)
Q: .. . Did Mr. Epstein ever threaten you in any manner?
A: No.
(see Depo Transcript 131:2-4)
In fact testified that she enjoyed going to Epstein's home:
Q: Did you enjoy the occasions when you went to Mr. Epstein's?
A: Yes. Like enjoyed collecting the money, yes.
Q: Well, you enjoyed what you were doing, didn't you? You enjoyed
spending time with him?
A: Not exactly spending time with him. I enjoyed going to be able to
collect that much money.
(see Depo Transcript 141:10-16)
enjoyed collecting the money so much that she, herself, initiated contact
in order to schedule visits to collect that money:
Q: Well, there were also occasions when no one from Mr. Epstein called,
but rather you called Mr. Epstein's and asked to go?
A: Yes.
Q: And that was because you wanted to go and earn some money,
correct?
EFTA_R1_00018832
EFTA01735439
A: Yes.
(see Depo Transcript 137:7-13)
Nevertheless claimed in her deposition that specifically because of her
interactions with Epstein:
A: I have a very hard time working around older men or in specific
situations.
Q: What situations would those be?
A: I don't trust anybody and I don't feel safe in some places.
Q: Well, you say you don't trust anybody?
A: Well, I don't trust men.
Q: What—any kind of particular kind of men or just -
A: Older men.
Q: And what's your definition of "older"?
A: Above 40.
(See Depo Transcript 66:10-21)
Yet, despite her claimed "trust" issues with men over 40 years old,
admitted under oath at her deposition that, after she stopped seeing Epstein:
A: I was working for an
Q: And what was the name of that
A:
Q: That wou d • e two separate
A: Yes.
(see Depo Transcript 68:12-18)
Q: And thereafter
A: Yes.
(See Depo Transcript 75:21-24).
Incredulously
Q:
EFTA_R1_00018833
EFTA01735440
A: Yes.
Q:
A: Yes, that's true.
(see Depo Transcript 67:15-20)
and
A: Yeah.
(see Depo Transcript 82:12-16)
III. Deposition o
Althoug.also claimed in her civil case injury from her interactions with
Epstein, her sworn deposition testimony clearly establishes that any injuries that
been interacting with Epstein:
Q: Now, read to the ladies and gentlemen of the jury what you wrote
occurred on 2004 wit
A:
hone
EFTA_R1_00018834
EFTA01735441
Q:
A:
(see epo ranscrip : - :
oug era missions l uring e eposition
indicate that it was earlier than that):
: Now, it's a fact, is it not, that b the be 'nnin of ou b
A: Yeah.
(see Depo Transcript 180:7-11)
A:
Q:
A:
Q:
(see Depo Transcript 181:21-182:2)
Q: Are you - did you
A: Yeah.
(see Depo Transcript 183:19-21).
was then
Q:
A:
Q: hen you first started dating him,
right?
A: Yes, somewhere in that time - I'm pretty sure it's somewhere in that
time frame.
(see Depo Transcript 198:3-11)
A:
(see Depo Transcript 199:17-21)
EFTA_R1_00018835
EFTA01735442
Q:
A: Yeah.
iaa
A:
(see Depo Transcript 202:10-22)
Nevertheless
A: I have made
Q: ... what did thi
A:
Q:
A:
Q:
A:
Q:
A:
(see l epo
Q: When you made the
A:
Q:
A:
Q:
EFTA_R1_00018836
EFTA01735443
A: Yeah.
A: Yeah.
Q•
A:
Q:
A:
Q:
A:
Q: Tell the ladies and : entlemen, look in the camera and tell the ladies
and entlemen of the jury
A:
(see Depo Transcript 361:20-368:8)
Q:
A:
Q:
A:
EFTA_R1_00018837
EFTA01735444
Q:
A:
Q:
A:
(see Depo Transcript 324:24-325:10)
Q:
A:
Q:
A:
Q:
A:
Q:
A: One of those two.
(see Depo Transcript 326:23-327:9)
Q:
A: Three.
(see Depo Transcript 299:16-21)
Q:
A:
Q:
...
A:
Q:
A:
(see epo ranscript
Q:
A:
Q:
A:
(see epo ranscript
Q:
EFTA_R1_00018838
EFTA01735445
Q: Is that right?
A: Yeah.
(see Depo Transcript 426:9-16)
A: Yeah, probably.
(see Depo Transcript 213:11-25)
Q: Okay. And it was - it was when you were 17, between the ages of 17
and 18?
A: Uh-huh.
(see Depo Transcript 25:17-26:1)
Q: You had before you met Mr. Epstein, had you not?
A: Yeah.
(see Depo Transcript 221:3-5)
I want to ask you again, did you ever do
EFTA_R1_00018839
EFTA01735446
(see Depo Transcript 214:24-215:4)
ttlir
A:
(see epo ranscrip
Q:
A:
(see Depo Transcript 217:19-23)
a s attempted to blame E stein for an in'uries she claims to have sustained
durin the eriod
tell [Epstein] your age" (see Depo
ranscript : - . oreover
Q: Didn't have any sexual relations with Mr. Epstein did you?
A: No.
(see Depo Transcript 180:12-14)
Q: And by the way, did you - did you ever touch Mr. Epstein's penis?
A: No.
(see Depo Transcript 361:5-7)
Q: Did he ever physically hurt you in any manner whatsoever?
A: No.
Q: Did he ever demean you in any manner whatsoever?
A: No.
(see Depo Transcript 169:16-25)
Q: Mr. Epstein never gave you drugs, correct?
A: No.
(see Depo Transcript 221:12-14)
An
l admitted during her deposition:
Q: Was Mr. Epstein good to you?
A: Yeah.
(see Depo Transcript 122:9-10)
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Q: And Mr. Epstein, as you said before lunch, was very nice towards you,
was he not?
A: Yeah.
A: He was really nice, like friendly.
(see Depo Transcript 168:9-20)
In factindmitted that from the period of time after she was of legal age and
legally deemed able to make her own decisions regarding her interactions with
Epstein, she voluntarily saw Epstein as much as 50 times:
: Can ou tell me how man times ou went to Mr. Epstein's between
A: Well, approximately, approximately like 30 to 50 times.
Q: Okay. You went voluntarily. Nobody forced you to go to Mr. Epstein's,
correct?
A: Yeah.
(see Depo Transcript 77:17-79:4)
MoreoveMdmitted under oath that when■ first learned of the claims against
Epstein and before she filed her law suit against Epstein "was like defendin
Mr. E stein" (see Depo Transcript 276:2), and thatMan er frien
discussed and told others that such claims were outrageous:
Q: Did you ever, at any point in your life right up until today tell anyone
that you thought it was outrageous that anyone would file a lawsuit against
Jeffrey Epstein because everybody knew what the deal was and knew what
they were doing or words to that effect?
A: Yeah, I said that because I didn't even think I was doing
anything wrong at the titjra
...
A: We, she said we both said to each other. We were just, like, I can't
believe this is happening, like Jeffrey is such a great guy, like, you know, like,
saying all this stuff about, about him...
(see Depo Transcript 275:18-277:2)
Q: All right. • ' • that you have made this statement to
people other than between January of '06 and January of '09,
that everybody tha wen o see e rey Epstein knew exactly what they were
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getting into, did it voluntarily, and it's outrageous that they would sue him?
A: Yeah.
Q: Now, I want to tell you that you filed your lawsuit in 2008. Okay. You
can assume and I'm sure your counsel will correct me if I'm wrong, but you
didn't file this lawsuit until 2008. You had a lot of conversations with your
friends that had gone to Jeffrey Epstein before you filed this lawsuit, didn't
you?
A: Yeah.
Q: And all those conversations were that everybody knew what they
were getting into, and it was all done voluntarily, and at that time you-all
thought it was crazy that anybody would sue Jeffrey Epstein, didn't you?
A: Yeah.
(see Depo Transcript 282:8-25)
Finallyalso admitted that even after the police contacted her when she was in
college and of legal age, but before she had retained legal counsel in her civil case,
she "probably more than likely" would have continued to see Epstein. See Depo
Transcript 393:10-16.
claims against Epstein de& credibility. She was consistently evasive
during her deposition. She admitted in her deposition to lying under oath and to
'on interviews with her own experts, includin about such things as
see Depo Transcript 402:22-403:2) an
see Depo Transcript 405:2-406:9). Most tellingl dmitted:
Q: So, we don't really know, even when you're under oath, whether
you're telling the truth or you're lying, do we?
A: No.
(see Deposition Transcript 401:7-10)
In light ofher admitted
the entire period that she claims to ave een interacting with Epstein, her evasive
responses to direct deposition questions, her admitted deceptions to her own
experts, her revelation that her testimony cannot be relied upon, even under oath,
her admissions regarding her positive personal feelings about Mr. Epstein and her
re-litigation characterization of the civil claims against Epstein as outrageous,
• civil claims of injury by Epstein do not withstand scrutiny.
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DataSet-10
Unknown
19 pages
NOTES OF QUOTES AND STATEMENTS FROM DEPOSITION TRANSCRIPTS
I. Deposition of s
Although M. has sought in her civil case against Epstein to portray herself
as an innocent, who was damaged by her interactions with Epstein, both her
behavior and her own sworn statements during the course of her deposition in her
civil case belie her claims. Repeatedly throughout the course of her deposition, M.
engaged in the frequent use of profanity and personal attacks on Epstein's counsel.
For example, during her deposition, M. made the following comments:
A: You're an asshole.
Q: You were a -
A: You're a fucking asshole.
(see Depo Transcript 130:10-19)
A: You are just fucking sitting here making money.
(see Depo Transcript 132:9-10)
Q: Ok, you were partying, right?
A: Yeah, like normal people do like you're going to probably do after this
with all your fucking money.
(see Depo Transcript 133:3-5)
Q: ... Let's be honest.
A: Okay. Let's be honest.
Q: Did you ever send?
A: Yeah jackass. You're a fucking asshole.
(see Depo Transcript 225:19-23)
In fact, M's use of profanity was so egregious and disruptive during her
deposition that the court a eed to extend her deposition for six hours and ordered
her attorney to caution M. against engaging in such further inappropriate behavior:
But the witness should be warned that the Court will not tolerate any further
vulgarities, any further accusations without merit relative to counsel, any
further attacks on counsel, any references to counsel's children or anything
of that nature.
I will allow the deposition ... without interruptions of the same type that
we witnessed by virtue of my reading of this transcript on several occasions
now, to last another six hours, total. Period.
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EFTA02725090
I want to put on record that the vulgarities, the attacks on counsel, the
attacks of a personal nature that were communicated by E. were such that,
if they are repeated, that sanctions will be assessed, and those sanctions
could include the striking of the pleadings.
(see November 3, 2009 Hearing Transcript 9:20-10:23)
In addition to her "vtigar" behavior during her deposition, M. admitted
during the deposition that M. "started drinking, partying and having fun, when I
was around 15, I guess....14 going into 15" (see Depo Transcript 304:19-22). She
admitted under oath that "1lost my virginity when I was 14 years old: (see Depo
Transcript 109:17-18). She also admitted that she did "any drugs I could get, coke,
pain killers. I have done many drugs, ecstasy and -- ... and Xanax." (see Depo
Transcript 86:12-15) She testified that she started using drugs when "I was in
seventh and eight and ninth. Not when I was in seventh. More when I was in eighth
and ninth: (see Depo Transcript 86:22-24) She admitted, however, that Epstein
never provided a with any drugs or alcohol:
Q: Jeffrey Epstein never gave you any drugs did he?
A: No.
Q: He was an antidrug person, wasn't he?
A: That's what he said.
Q: And he made that pretty clear to you?
A: Yes.
Q: Never gave you alcohol, right?
A: Never.
Q: Told you he didn't believe in alcohol. Didn't drink it himself, right?
A: True.
Q: Always treated you well when you were at his house, didn't he?
A: Of course.
(see Depo Transcript 305:5-306:1)
E. also testified under oath that she and her friend, M., worked as topless
dancers at a strip club when M. was only fourteen or fifteen years old:
Q: Okay, when you thou ht 1 was 14, at what club was she dancing?
A: We both went to
•••
A: When we were, when we were 14, we went there like once or twice.
•••
Q :
So, you went in there at age 14 with her? Were you 14 at the time?
A: Yes. She might have been 15. I was maybe just turned 15.
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Q: What did you do [at
A: I was an entertainer.
Q: And then when you say you were entertainment, what did you do?
A: I was a dancer.
Q: Meaning you got up on stage, right?
A: Yes.
Q: Took your top off, right?
A: Yes.
Q: Did you do lap dances?
A: Not at this particular club.
Q: You have done them at other clubs?
A: Yes.
(see Depo Transcript 299:2-300:21)
M. also testified that she "probably" told Epstein that she worked at that strip club.
(see Depo Transcript 300:3-4)
E. also admitted that she was a call girl/escort since the age of 15. She
testified at her deposition: "Well, I lived life as a prostitute" (see Depo Transcript
156:7), "I am a prostitute when I make money" (see Depo Transcript 156:12-13),
and "I was a call girl and I worked for myself.... From the age of 15 to the age of 21"
(see Depo Transcript 280:16-19). In fact, admitted to making $1,000 a day or
e
more from prostitution on "maybe" more than 20 occasions in one year alone:
Q: You earlier said that in the year 2008, some days you made a
thousand dollars a day, some days you made $2,000 a day. How many days
out of the year would you say you made a thousand dollars a day or more a
day in the year 2008?
A: I don't know.
Q: Was it more than ten?
A: Maybe.
Q: Was it more than 20?
A: Maybe.
(see Depo Transcript 157:11-159:6).
M. also admitted under oath to keeping a list of amounts she collected from her
johns in "two or three" lined books that she kept for the years "06, 07, 08 and 09"
(see Depo Transcript 59:13-64:12), including a book of "Psalms" that she obtained
from a religious store (see Depo Transcript 152:1-14).
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EFTA02725092
M. attempted to lay blame on Epstein during her deposition for, among
other things, her life as a prostitute. (see Depo Transcript 129:5-23). Yet M.
admitted that she never had sexual intercourse with Epstein and never touched
Epstein's penis:
Q: You never had sexual intercourse with Mr. Epstein, did you?
A: Penis inserted into the vagina, no.
Q: Did he ever insert his penis into your mouth?
A: No.
Q: Did he ever insert his penis into your anus?
A: No.
Q: Did he ever insert his penis into your vagina?
A: No.
Q: Did you ever hold his penis in your hand?
A: No.
(see Depo Transcript 71:15-72:9)
Moreover, sworn deposition testimony from , the person who first
brought M. to Epstein's home, indicates that . engaged in prostitution before
M. ever met Epstein. In her deposition, Ms. testified that on Ms second
visit to Epstein's home, M. quoted to Epstein rices for various sexual favors
that M. and C's mother performed. Ms. testified that M. was "telling
[Epstein] about some stuff that her mom and her did sexually for money or some
stuff like that" (see Depo Transcript of=. 280:9-11) and that M. was "offering
information" to Epstein:
A: That her and her mom have had, her mom does things and has prices
for things. Something of that matter...
Q: Sexual nature?
A: Yeah.
(see Depo Transcript of=. 276:16-277:11)
11. Deposition of
Another woman claiming in her civil case to have lost her innocence to
Epstein is . Yet, Ms. sworn deposition testimony in her
civil case against Epstein paints quite a different picture. Ms. who during
her deposition appeared at times disoriented and even once fell asleep, testified
under oath to a pervasive history of illegal drug abuse. For example:
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EFTA02725093
Q: You have used a number of illegal drugs in the past, have you not?
A: Yes, I have.
Q: And what drugs have you used in the past?
A: Cocaine, marijuana, pain pills, Morning Glories, Angle Trumpets, acid,
Ecstasy.
Q: Heroin?
A: Yep, I've tried heroin.
Q: You have tried crystal meth?
A: Yeah...
(see Depo Transcript 87:11-88:8).
Ms. admitted that she began smoking marijuana before she ever met
Epstein (see Depo Transcript 274:11-13). In addition, she testified:
Q: And you started using marijuana at age what?
A: Thirteen.
Q: And you used it with what degree of frequency?
A: I don't know, every day.
(see Depo Transcript 274:14-19)
She further admitted that she altered Roxicodone pills to take the drug
intravenously because "it wasn't working for me swallowing it anymore" and
because "it hits you faster" (see Depo Transcript 97:14-20). She also testified that "I
told [Wellington Regional Hospital] I was an IV drug user." (see Depo Transcript
271:20-23).
Like, M., Ms. confirmed under oath that Epstein never gave or even
offered her drugs or alcohol:
Q; Mr. Epstein never gave you any drugs, did he?
A: No.
(see Depo Transcript 103:8-10)
Q: He never told you to use drugs in his house, did he?
A: No, he never told me to.
Q: He never gave you alcohol in his house, did he?
A: No.
(see Depo Transcript 106:7-12)
Q: He never attempted to drug you in any manner, did he?
A: No.
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EFTA02725094
Q: Never even offered you drugs, correct?
A: Correct
(see Depo Transcript 131:13-17)
In addition to her pervasive history of drug abuse, Ms. also admitted
in her deposition that she had a long history of sexual activity since the age of 12,
well before she ever met Epstein:
Q: So, by, by your acknowledgement in these answers to interrogatories
before you ever went to Mr. E • stein's house the first time, ou had had
sexual relations with and
somebody whose last name you can't remember, and -
A: And that's it.
Q: And
A: No.
Q: Not but up through M?
A: Yes.
(see Depo Transcript 258:6-16)
Q: Okay. And when was the first time that you had a sexual experience
with another woman?
A: When I was 12.
Q: and who was this other woman?
A: My ex-girlfriend.
(see Depo Transcript 161:18-22)
Ms. and one of her bo friends even filmed themselves having sexual
intercourse when Ms. was just 13 years old:
Q: ... When were you filmed in the nude?
A: With one of my boyfriends.
Q: And when was he your boyfriend?
A: I was 13.
Q: Excuse me?
A: When I was 13.
Q: Was this before or after the point in time that you had your
relationship with
A: It was after. Well, it was before. I don't - It was like during type of
thing. Even though she was my girlfriend, we still had boyfriends if that
helps you.
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EFTA02725095
Q: But the film was of the two of you together as supposed [sic] to just
you alone?
A: Yes.
Q: And what were you and he doing in the film?
A: Having sex.
Q: Just intercourse?
A: Yeah.
(see Depo Transcript 200:25-202:5)
Ms. testified that her first child was born "when I was 17." (see Depo
Transcript 204:10-11). She testified to having a sexual relationship with the father
of that child since she was 13 years old:
Q: When did you first meet
A: When I was 13.
Q: Did you, did you meet him before you first went to Mr. Epstein's?
A: Yes.
Q: Had you had a sexual relationship with obviously?
A: Yes.
Q: Had you had sex with before you went to Mr. Epstein's for
the first time?
A: Yes.
Q: And what sexual acts had you engaged in with before you
went to Mr. Epstein's?
A: Intercourse.
Q: And did you consider to be your boyfriend?
A: Yeah.
Q: And you were dating him during the entire period of time that you
went to Mr. Epstein's
A: Yeah.
Q: And did ever physically bring you to Mr. Epstein's house?
A: Yes.
Q: ... Ever any occasion when brought any females that he
dropped off at Mr. EsItein's other than -
A: Yes, me and E. and me and E.
(see Depo Transcript 207:20-209:17)
Ms. testified about having a frighteningly violent and tumultuous
history with this boyfriend. For example:
A: He cheated on me with and I suppose he felt guilty about it. So, he
tried to say I was cheating on him and I wasn't cheating on him. He was
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cheating on me and he felt guilty, and then decided he was going to try to kill
me.
Q: And you were afraid - where were you when this gun was held to
your head?
A: In the middle of a field.
(see Depo Transcript 258:22-259:4)
Q: For approximately how long did the event take place thaaeld
a gun to your head?
A: Like five minutes and then we kissed and made up and had sex.
Q: In the field?
A: Yep.
(see Depo Transcript 260:24-261:4)
Q: Was there another occasion that ivas physically violent
towards you?
A: Yes.
Q: When was that?
A: When he tried to drown me in a canal.
(see Depo Transcript 261:15-19)
Epstein even counseled Ms. against continuing her relationship with this
violent man, but Ms. ignored Epstein's advice:
Q: And when did you tell Mr. Epstein about it?
A: On one of the occasions I went to his house.
Q: And what did he say?
A: I don't know. He talked to me about it.
Q: Was he sympathetic toward you?
A: A little bit
Q: Did he tell you you ought to get away from this guy?
A: Yeah.
Q: Did you pay attention to what he said?
A: Obviously not, if I had a kid with him some years later.
(see Depo Transcript 262:5-17)
Despite Ms. established history of drug abuse originating prior to her
meeting Epstein and long history of sexual activity with members of both the same
and opposite sexes that predated her interactions with Epstein, Ms. claims
injury by Epstein in her civil case. She makes these claims even though she made
the following admissions in her deposition:
Q: Did you ever have sexual intercourse with Mr. Epstein?
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A: No.
(see Depo Transcript 106:13-15)
Q: Did you ever touch Mr. Epstein's penis -
A: No.
Q: -- in any way?
A: No, no.
(see Depo Transcript 109:1-4)
Q: All right. Would you, would you say that during the period from
May '02 to August '03 Mr. Epstein was good to you?
A: Yes.
(see Depo Transcript 127:23-128:1)
Q: Did he ever, did he ever strike you ever, hit you?
A: No.
Q: Did he ever commit an act of domestic violence against you?
A: No.
(see Depo Transcript 129:2.10)
Q: .. . Did Mr. Epstein ever threaten you in any manner?
A: No.
(see Depo Transcript 131:2-4)
In fact, Ms. testified that she enjoyed going to Epstein's home:
Q: Did you enjoy the occasions when you went to Mr. Epstein's?
A: Yes. Like enjoyed collecting the money, yes.
Q: Well, you enjoyed what you were doing, didn't you? You enjoyed
spending time with him?
A: Not exactly spending time with him. I enjoyed going to be able to
collect that much money.
(see Depo Transcript 141:10-16)
Ms. enjoyed collecting the money so much that she, herself, initiated contact
in order to schedule visits to collect that money:
Q: Well, there were also occasions when no one from Mr. Epstein called,
but rather you called Mr. Epstein's and asked to go?
A: Yes.
Q: And that was because you wanted to go and earn some money,
correct?
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A: Yes.
(see Depo Transcript 137:7-13)
Nevertheless, =. claimed in her deposition that specifically because of her
interactions with Epstein:
A: I have a very hard time working around older men or in specific
situations.
Q: What situations would those be?
A: I don't trust anybody and I don't feel safe in some places.
Q: Well, you say you don't trust anybody?
A: Well, I don't trust men.
Q: What—any kind of particular kind of men or just -
A: Older men.
Q: And what's your definition of "older"?
A: Above 40.
(See Depo Transcript 66:10-21)
Yet, despite her claimed "trust" issues with men over 40 years old, Ms.
admitted under oath at her deposition that, after she stopped seeing Epstein:
A: I was working for an escort service.
Q: And what was the name of that escort service?
A:
Q: That would be two separate escort services?
A: Yes.
(see Depo Transcript 68:12-18)
Q: And thereafter, after you were employed, did you on numerous
occasions go out with men over 40 years of age?
A: Yes.
(See Depo Transcript 75:21-24).
Incredulously, Ms. claimed in her deposition that on the occasions when she
went out with people that were over 40 years old, she would only go "to dinner or
to go out dancing" or "to a movie or to like an event that they had to go" (see Depo
Transcript 83:11-16), that she told the escort services that "I would not do anything
sexual with anybody" (see Depo Transcript 75:18-19), and that if somebody tried
to do something sexual with her, then "I left" (see Depo Transcript 84:5-10).
Though she claimed that nothing sexual happened with her clients, according to her
testimony, somehow:
Q: ... you have made as much as a thousand dollars a night -
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A: Yes.
Q: -- going out with people, men that are over 40, have you not?
A: Yes, that's true.
(see Depo Transcript 67:15-20)
and
Q: Is it true that the amount of money that you earned with
and with was the most you ever earned as a wage in your
life?
A: Yeah.
(see Depo Transcript 82:12-16)
III. Deposition of
AlthoughM. also claimed in her civil case injury from her interactions with
Epstein, her sworn deposition testimony clearly establishes that any injuries that
she may have sustained were the result of a dangerous and violent relationship that
she carried on with another man during the entire period that she claims to have
been interacting with Epstein:
Q: Now, read to the ladies and gentlemen of the jury what you wrote
occurred on Setpember 20th, 2004 with Mr. Vinyard.
A: Preston and I were laying in bed. When a guy friend called my cell
phone, Preston said that I was a slut, whore, cunt that was cheating on, that I
was cheating on him. Preston started checking, checking, I don't even -
Q: Choking?
A: -- yeah, choking me into the mattress, and then when I went into my
purse, he threw me against the wall and started yelling at me. Then Preston
pushed me out the door. And whenever I asked for the rest of my belongings,
he told me to wait
Whenever he came back, he spilled a bear all over and threw
cigarettes it in my face and slammed me into the ground. I got up. I went to
my car and he followed me.
A: Shut my door and he opened it. He spit in my face and he continued to
call me a whore, a slut, and cunt I shut the door, and he opened it again, and
he got in my face, grabbed my arms very hard[] Mo make him let go[,] I bit
his arm. I bit his arm and he bit me back on my finger and cut it open. He
was, he was biting so hard that he was repeating - he repeatedly harassed
me since last night ...
Q: Would you treat a dog like this?
A: No.
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Q: No human being ought to be treated like this, should they?
A: No.
(see Depo Transcript 357:6-360:4)
M. admitted under oath thatM. was engaged in a sexual relationship with this
abusive man since the age of 16 (though her admissions during the deposition
indicate that it was earlier than that):
Q: Now, it's a fact, is it not, that by the beginning of your junior year, by
the beginning of let's say, August of '03, you were having sexual relations
with a Preston Vinyard, weren't you?
A: Yeah.
(see Depo Transcript 180:7-11)
Q: Okay. So, Mr. Vinyard had taken his penis and inserted it in your
vagina before your junior rear of high school; isn't that right?
A: Yeah, I think so, yeah.
Q: Had you given him oral sex before your -
A: Yeah.
Q: -- junior year of high school?
(see Depo Transcript 181:21-182:2)
Q: Are you - did you - are you claiming you lost your virginity to Preston
Vinyard?
A: Yeah.
(see Depo Transcript 183:19-21).
M. testified that when she began this sexual relationship with this abusive man, he
was then a 23 year-old adult, 7 years older than she, had been in prison and was an
alcoholic:
Q: When was the first time you went over to his house?
A: When I was 16.
Q: Sixteen. Okay. He's 23 and your 16 when you first started dating him,
right?
A: Yes, somewhere in that time - I'm pretty sure it's somewhere in that
time frame.
(see Depo Transcript 198:3-11)
A: Well, when I first started dating him, he [my father] didn't really know
that - how old Preston was. He didn't know that he had a criminal
background until later on -
(see Depo Transcript 199:17-21)
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A: There was a time, where he, he would drink a lot. He was an alcoholic
and he would get out of control when he drank...
(see Depo Transcript 28:11-29:23)
Because of Mr. Vinyard's severe violence and abuse against her,. obtained a
restraining order against him during her junior or senior year of high school:
Q: Did you say you got a restraining order against him?
A: Yeah.
Q: And what year of high school were you in when you got the
restraining order against the first love of your life, Mr. Vinyard, who you now
say is abusive to you?
A: I think it was my junior or senior year.
(see Depo Transcript 202:10-22)
Nevertheless, both before and after she obtained this restraining order, M.
continued to maintain a sordid and damaging sexual relationship with Mr. Vinyard.
For example, M. admitted under oath that she made a homemade video of her
sexual exploits with Mr. Vinyard from her bedroom in her parents' house using her
parents video equipment while M. was in high school:
A: I have made a homemade video before.
Q: ... what did this homemade video depict?
A: Me and my boyfriend.
Q: At the beach or -
A: -- making out together.
Q: having sex?
A: Yeah.
Q: Having sexual intercourse?
A: Yeah.
(see Depo Transcript 226:11-227:7)
Q: When you made the videotape of you and Preston having sexual
relations, what acts were recorded on the videotape?
A: On the tape?
Q: Yeah, the tape -
A: Sex.
Q: You used your parents' video camera -
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A: Yeah.
Q: -- to record you and this fellow, Preston Vinyard, engaged in sexual
relations?
A: Yeah.
Q: Where did the actual filming take place?
A: In my, my house.
Q: What house?
A: My room.
Q: The room, the house your parents owned?
A: Yeah.
Q: Tell the ladies and gentlemen, look in the camera and tell the ladies
and gentlemen of the jury you don't know if you were in high school when
you made this tape.
A: I was in high school when I made this with Preston.
Q: So, tell me what specific acts you engaged in with Mr. Vinyard that you
then recorded on this video, to your parents' videotape machine in your
parents' home.
A: Of us having sex.
Q: I want to know the specific acts. Did it reflect oral sex?
A: Sure.
Q: Were you, did it reflect you having Preston Vinyard's penis in your
mouth?
A: Yeah.
Q: Did it - show him licking your vagina?
A: Yeah.
Q: Did it - did he insert his penis in your vagina on this tape?
A: Yeah.
(see Depo Transcript 361:20-368:8)
M. also testified that she caught herpes from Mr. Vinyard when she was 15 or 16
years old:
Q: Where did you get the herpes from?
A: The one person I was sleeping with.
Q: Well, who is that?
A: Preston.
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Q: Do you remember when you got the herpes?
A: Yeah.
Q: Still in high school at the time?
A: Yeah.
(see Depo Transcript 324:24-325:10)
Q: How old were you at that time?
A: No, I don't remember?
Q: Fifteen?
A: I don't remember.
Q: Well that was before you got pregnant, right?
A: Yeah could have been like when I was 16.
Q: Okay. So 15 or 16?
A: One of those two.
(see Depo Transcript 326:23-327:9)
admitted to having three abortions when she was with Preston Vinyard, two of
which occurred while she was in high school and two of which occurred after she
obtained the restraining order against Mr. Vinyard:
Q: How many abortions have you had?
A: Three.
(see Depo Transcript 299:16-21)
Q: All right. When did you have your first abortion?
A: Sixteen.
Q: Which would have been - what year was that?
A: It might have been my sophomore or junior year. I don't remember.
Q: Sophomore or junior year in high school?
A: Yeah.
(see Depo Transcript 311:7-21)
Q: When was your second abortion?
A: In my senior year in high school.
Q: That was when you were 17?
A: Yes.
(see Depo Transcript 312:23-313:1)
Q: So, after you got an injunction against domestic violence, you hooked
up with Preston Vinyard again and got pregnant with him again, and had
EFTA_R1_02212540
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another abortion with him; is that right?
Q: Is that right?
A: Yeah.
(see Depo Transcript 426:9-16)
M. admitted that she began drinking alcohol before she was even 16 years old and
that during her relationship with Preston Vinyard, she was drunk with him twice a
week:
Q: And do you recall when you first started drinking?
A: No. I don't remember the first time I started drinking, but - no, I don't.
Q: Was it before you were 16?
A: Maybe, yeah.
Q: And how many times were you drunk with old Preston?
A: I don't even know that answer. I don't know.
Q: Well, Preston testified yesterday that you were drunk about twice a
week with him. Would you agree with that estimate from him?
A: Yeah, probably.
(see Depo Transcript 213:11-25)
M. was even arrested for DUI when she was 17 years old:
Q: Okay. And it was - it was when you were 17, between the ages of 17
and 18?
A: Uh-huh.
Q: And what were you arrested for?
A: DUI
(see Depo Transcript 25:17-26:1)
M. also admitted that before and during the course of her relationship with Mr.
Vinyard, M. used illegal drugs, including marijuana, cocaine and ecstasy:
Q: You had smoked pot before you met Mr. Epstein, had you not?
A: Yeah.
(see Depo Transcript 221:3-5)
Q: I want to ask you again, did you ever do any drug with Mr. Vinyard
that you didn't have any prescription for?
A: Yeah.
Q: What drugs?
A: Coke.
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EFTA02725105
(see Depo Transcript 214:24-215:4)
Q: Any pills that you have taken before that you didn't have a
prescription for?
A: Yeah, I have tried ecstasy.
(see Depo Transcript 217:4-6)
Q: For what period of time did you take ecstasy?
A: I didn't. It's not like I took it every day. It's not like I took it every day.
On occasion, I tried it
(see Depo Transcript 217:19-23)
M. has attempted to blame Epstein for any injuries she claims to have sustained
during the period that she was engaged in this unfortunate and abusive relationship
with Preston Vinyard. This is so even though admitted in her deposition that
she was specifically told by "Don't tell [Epstein] your age" (see Depo
Transcript 62:17-22). Moreover, . testified:
Q: Didn't have any sexual relations with Mr. Epstein did you?
A: No.
(see Depo Transcript 180:12-14)
Q: And by the way, did you - did you ever touch Mr. Epstein's penis?
A: No.
(see Depo Transcript 361:5-7)
Q: Did he ever physically hurt you in any manner whatsoever?
A: No.
Q: Did he ever demean you in any manner whatsoever?
A: No.
(see Depo Transcript 169:16-25)
Q: Mr. Epstein never gave you drugs, correct?
A: No.
(see Depo Transcript 221:12-14)
And M. admitted during her deposition:
Q: Was Mr. Epstein good to you?
A: Yeah.
(see Depo Transcript 122:9-10)
EFTA_R1_02212542
EFTA02725106
Q: And Mr. Epstein, as you said before lunch, was very nice towards you,
was he not?
A: Yeah.
A: He was really nice, like friendly.
(see Depo Transcript 168:9-20)
In fact, M. admitted that from the period of time after she was of legal age and
legally deemed able to make her own decisions regarding her interactions with
Epstein, she voluntarily saw Epstein as much as 50 times:
Q: Can you tell me how many times you went to Mr. Epstein's between
June 1d of 2005 and Octoer 31st of 2005?
A: Well, approximately, approximately like 30 to 50 times.
Q: Okay. You went voluntarily. Nobody forced you to go to Mr. Epstein's,
correct?
A: Yeah.
(see Depo Transcript 77:17-79:4)
Moreover, M. admitted under oath that when M. first learned of the claims against
Epstein and before she filed her law suit against Epstein, M. "was like defending
.Eirin" (see Depo Transcript 276:2), and that M. and her friend,
Mi. discussed and told others that such claims were outrageous:
Q: Did you ever, at any point in your life right up until today tell anyone
that you thought it was outrageous that anyone would file a lawsuit against
Jeffrey Epstein because everybody knew what the deal was and knew what
they were doing or words to that effect?
A: Yeah, I said that to Lauren, because I didn't even think I was doing
anything wrong at the time...
A: We, she said we both said to each other. We were just, like, I can't
believe this is happening, like Jeffrey is such a great guy, like, you know, like,
saying all this stuff about, about him...
(see Depo Transcript 275:18-277:2)
Q: All right. Now, isn't it a fact that you have made this statement to
people other than , between January of '06 and January of '09,
that everybody that went to see Jeffrey Epstein knew exactly what they were
EFTA_R1_02212543
EFTA02725107
getting into, did it voluntarily, and it's outrageous that they would sue him?
A: Yeah.
Q: Now, I want to tell you that you filed your lawsuit in 2008. Okay. You
can assume and I'm sure your counsel will correct me if I'm wrong, but you
didn't file this lawsuit until 2008. You had a lot of conversations with your
friends that had gone to Jeffrey Epstein before you filed this lawsuit, didn't
you?
A: Yeah.
Q: And all those conversations were that everybody knew what they
were getting into, and it was all done voluntarily, and at that time you-all
thought it was crazy that anybody would sue Jeffrey Epstein, didn't you?
A: Yeah.
(see Depo Transcript 282:8-25)
Finally,M. also admitted that even after the police contacted her when she was in
college and of legal age, but before she had retained legal counsel in her civil case,
she "probably more than likely" would have continued to see Epstein. See Depo
Transcript 393:10-16.
M's claims against Epstein de& credibility. She was consistently evasive
during her deposition. She admitted in her deposition to lying under oath and to
lying in evaluation interviews with her own experts, including about such things as
her drug usage (see Depo Transcript 402:22-403:2) and her three aborted
pregnancies (see Depo Transcript 405:2-406:9). Most tellingly,M. admitted:
Q: So, we don't really know, even when you're under oath, whether
you're telling the truth or you're lying, do we?
A: No.
(see Deposition Transcript 401:7-10)
In light ofher admitted violent and sordid history with Mr. Vinyard during
the entire period that she claims to have been interacting with Epstein, her evasive
responses to direct deposition questions, her admitted deceptions to her own
experts, her revelation that her testimony cannot be relied upon, even under oath,
her admissions regarding her positive personal feelings about Mr. Epstein and her
re-litigation characterization of the civil claims against Epstein as outrageous,
M's civil claims of injury by Epstein do not withstand scrutiny.
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7 pages
NOTES OF QUOTES AND STATEMENTS FROM
DEPOSITION TRANSCRIPTS OF IM. AND M.
I. Deposition of a
During her sworn deposition in her civil case against, Jeffrey Epstein, M.
admitted that she never traveled any place with Jeffrey Epstein and never
communicated with Jeffrey Epstein by computer.
Q: Did you ever travel anyplace with Jeffrey Epstein?
A: Nope
* **
Q: Did you ever communicate with Jeffrey Epstein on the computer?
A: No not that I recall.
(MM
By the admissions in her sworn testimony it is clear that M. was not
persuaded by Jeffrey Epstein by Internet or telephone to engage in unlawful sexual
activity with Jeffrey Epstein.
M. was first brought to Jeffrey Epstein by who M. met
in person. M. had no contact with Jeffrey Epstein prior to being brought to Jeffrey
Epstein's house by .
A: She brought me to Jeffrey's the first time.
Q: How did you know this person?
A: I was at a house and I am not exaeSvas at one of my friend's house. And
I spent the night over there. And I guess was one of my friend's friend. And
she asked me if l wanted to make $200. And at first I was very, very skeptical about
it because of the wa she ex lained it to me. But then she convinced me into it.
Q: So it was this person named that you say convinced you to go to
Jeffrey Epstein the first time, is that - do I have your testimony correct on that?
A: Yes, you do.
Q: Jeffrey Epstein had no contact with you until M, whatever her last name
is, brought you to his house; is that correct?
A: That's correct.
continued to take M. to Jeffrey Epstein's house for about a month's
time. After that M. obtained Mr. Epstein's telephone number and called herself to
make appointments.
A: After a couple of months, we hung out and that's when I got Jeffrey's number.
And I didn't, I did not no longer need her to take me to Jeffrey's. So we hung out a
EFTA_R1_00008349
EFTA01733706
couple of times. We would talk about Jeffrey and how much money we were making
from Jeffrey and that's that.
Q: What do you mean you no longer needed her to get to Jeffrey's?
A: I had Jeffrey's phone number, so I could call him, so he could send a taxi over,
or he could send somebody from house to come pick me up to go to Jeffrey's. I
didn't need her or one of her friends to drive me to eff, to Jeffrey's anymore. * * *
Q: And this occurred when, that is, that never - stopped taking you
there and you began to go over there on your own?
A: Within a month.
Q: During this period of time that you were going to see Mr. Epstein. Sometimes
you called and asked his people at his house whether, you know, you could come
work, did you not?
A: Yeah because he told me to call if I had a girl. So, I would call and ask if he
was available.
As is confirmed by •'s deposition testimony (excerpted below) in none of
the telephone calls was sexual conduct specifically discussed. Nor, given
history could it be reasonably argued that the telephone was used to persuade
to engage in any sexual conduct
also testified under oath that she and her friend, M., worked as topless
dancers at a strip club when was fourteen or fifteen years old:
Q: Okay, when you tart .] was 14, at what club was she dancing?
A: We both went to
A: When we were, when we were 14, we went there like once or twice.
Q: So, you went in there at age 14 with her? Were you 14 at the time?
A: Yes. She might have been 15. I was maybe just turned 15.
Q: What did you do [at
A: I was an entertainer. We went there two times and -
Q: Did you work there both times?
A: Yes.
Q: And then when you say you were entertainment, what did you do?
A: I was a dancer.
Q: Meaning you got up on stage, right?
A: Yes.
Q: Took your top off, right?
A: Yes.
Q: Did you do lap dances?
2
EFTA_R1_00008350
EFTA01733707
A: Not at this particular club.
Q: You have done them at other clubs?
A: Yes.
(see
M. also testified that she " robably" told Epstein that she was going to that
strip club. (see ), providing corroboration for claims that
Jeffrey believed she was of age.
M. also admitted that she was a call girl/escort since at least the age of 15
(though remarks she made to Epstein, as witnessed by - See below
- confirm that M. was engaged in prostitution before she met Epstein
testified at her deposition: "Well, I lived life as a prostitute" see
), "1 am a prostitute when I make money" (see ),
and "I was a call irl and I worked for myself. ... From the age of 15 to the age of 21"
(see a. In fact, admitted to making $1,000 a day or
more from prostitution on "maybe" more than 20 occasions in one year alone:
Q: You earlier said that in the year 2008, some days you made a
thousand dollars a day, some days you made $2,000 a day. How many days
out of the year would you say you made a thousand dollars a day or more a
day in the year 2008?
A: I don't know.
.
•
Q: Was it more than ten?
A: Maybe.
Q:
A:
(see
itr i
Was it more than 20?
be.
also admitted under oath to keeping a list of amounts she collected from her
johns in "two or three" lined books that she kept for the years "06, 07, 08 and 09"
(see includingi. al of "Psalms" that she obtained
from a religious store (see
M. attempted to lay blame on E stein during her I•c tion for, among
other things, her life as a prostitute. . However,
sworn deposition testimony from , the person who first brought
M. to Epstein's home, indicates that was a prostitute before she ever met
Epstein. In her dsaosition, testified that on C's second visit to
Epstein's home, M. quoted to Epstein rm rites of M. and 's mother for various
sexual favors that they perform. testified that was "telling [Epstein]
about some stuff that her mom and her did sexually for mone. some stuff like
that" (see of and that was "offering
information" to Epstein:
3
EFTA_R1_00008351
EFTA01733708
A: That her and her mom have had, her mom does things and has prices
for things. Something of that matter...
Q: Sexual nature?
A: Yeah.
(see of
Moreover, although M. claimed in her deposition that Jeffrey knew how old
she was, M. also admitted about lying about her age to everyone she came across,
including the strip clubs and prostitution businesses at which she worked beginning
at age 14 and 15.
Q: Earlier you said you worked for
A: Yes.
** *
A: I told them I was 19.
Q: Okay. Did you provide them with any kind of proof?
A: No.
Q: And why did you lie to them and tell them you were 19 if you were really 15?
A: Because I wouldn't be able to work there.
Q: Did you tell other people that you were older than you really were?
A: Yes.
Q: Who else did you tell that you were older than you really were?
A: Probably everybody I came across.
Q: So, that would be many people.
A: Yes.
Q: All of the various adult entertainment places you worked at. The places, the
topless bars you worked at, did you tell all of them you were older than you really
were?
A: The period of time when I worked at I told everyone I
was 19.
(See
[Note, however, that immediately after gave that answer in her testimony
she added (I presume to protect against these admissions) that "Jeffrey knew
how old I was. And Jeffrey knew hold old every girl I brought there was, and
he wanted young girls all the time."]
Q: Well worked at a place called when you were 14, didn't you?
A: . I told them I was 19 as well.
Q: When you were how old, 14?
A: Yes.
(See )
4
EFTA_R1_00008352
EFTA01733709
11. Deposition of
admited in her sworn deposition testimony that she never traveled with
Jeffrey Epstein and never exchanged emails or text messages with Mr. Epstein.
Q: Did you ever travel at any time with Mr. Epstein?
A: No.
Q: Did you ever email him at any time?
A: No.
***
Q: ... Would it be - it would be - did you ever have - exchange emails with Mr.
Epstein at any time?
A: No.
Q: Did you ever exchange text messages with Mr. Epstein at any time?
A: No.
Q: Did you ever travel with Mr. Epstein in any fashion at any time?
A: No.
(See
M. confirmed in her deposition that she was not persuaded by Mr. Epstein
by telephone to en age in sexual activi •. confirmed in her deposition that fl
first introduced M. to Mr.iutein. M. contacted Mr. Epstein by telephone to tell
him that she was bringing M. Mr. Epstein told M. that he would send a driver
and told M. where to meet the driver nothing else.
Q: Now, when you - when did you first go to Mr. Epstein's house?
A: I believe it was sometime in August 2002.
Q: And iff took you?
A: Yes.
(See
Q: What - what occurred during the conversation? What specifically was said?
A: That we were going to meet him - we were going to meet whoever his
drivers were at the shell gas station to pick us up.
Q: Who initiated the call?
A: She she called him and told him that she had a girl to bring to him.
(See
n,N.
As is true for also admitted in her deposition to having contacted
Jeffrey Epstein's home herself to ask to come to work for him.
Q: Did you ever request or contact Mr. Epstein's home and ask to come over to
work?
A: Yes
(See
5
EFTA_R1_00008353
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M. testified to speaking with or Jeffrey Epstein on the
phone, but as to all of those conversations, specifically testified that no specific
discussion regarding sexual activity ever took place over the telephone.
A: So he would - would ask me to call - see if I could come, and then I
would call him back directly, ask to talk to Jeffrey. Jeffrey wouldjat on the hone,
and I would confirm if I was coming or not. Yes, hi, Jeff, it's M.
7 No, M. Yeah, I'll be there at 3:00, I'll be there at 9:00p.m., I'll be there at
8:00, whenever the time was.
Q: Is the extent of the conversations that you had with Mr. Epstein, at least
when you would call back to confirm, it was hi, this is M., I'll be there at X time
period?
A: Pre much.
(See I
Whatever was said during M.'s telephone calls,
that at no time was the subject of sexual activity with
B testified very clearly
or anyone else ever
discussed with M. by telephone.
Would it be a correct statement that at no time did either Mr. Epstein or
1. or ever say to you over the telephone, whether you called or
they called you, that the massage would involve any sexual touching or any other
form of sexual conduct?
* *
*
A: No the never'Sc; col that over the phone. It was always face to face.
(See
M. admitted that every occasion that she went to Mr. Epstein's home was a
"knowing and voluntary decision" See 118:5-19). M. admitted
that Mr. E stein never threatened "No. He never said he was goin to hurt me"
- See . Mr. E stein never ave . drugs or
alcohol or encouraged use them. (See ).
Evidence from •'s testimony indicates that Mr. Epstein had every reason
to believe the M. was 18 years old. admited that she talked to Mr. Epstein
about working at the Strip = called when she first started seein
Mr. Epstein impliedly confirming to him that she was 18 (See
223:17-224:1). had a tattoo on her ankle with one of her professional names
, which admits normally requires that a person be 18 to receive. (See
. Moreover, M. admitted to going to night clubs
from the time she was 14 years old and never ever being carded at the doors of the
night clubs, indicating that she did not look underage from the time that she was 14
years old. (See I. In addition, M. was permitted to
work at strip clubs without showing ID when she was 14 ears old also indicating
that she appeared to be of age. (See . Evidence that
M. lied about her age is found in 's sworn deposition testimony where she
6
EFTA_R1_00008354
EFTA01733711
admits that she lied to the owner of that she was 18, and lied on her
applications to work at and that she was 18. (See
7
EFTA_R1_00008355
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giuffre-maxwell
Unknown
7 pages
EXHIBIT C
GIUFFRE
VS.
MAXWELL
Deposition
VIRGINIA GIUFFRE
05/03/2016
_______________________________________________________________________
Agren Blando Court Reporting & Video, Inc.
216 16th Street, Suite 600
Denver Colorado, 80202
303-296-0017
Agren Blando Court Reporting & Video, Inc.
1 filed under oath is no longer true, correct?
2 MR. EDWARDS: Object to the form.
3 A I wouldn't say that it wasn't true. I was
4 just unaware of the times and the dates.
5 Q (BY MS. MENNINGER) Again, is there more
6 than one truth, Ms. Roberts?
7 A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?
12 MR. EDWARDS: Object to the form.
13 A It's not that it's an untrue statement.
14 It was a mistake. So it wasn't intentionally trying
15 to say something that wasn't true. It was to my best
16 knowledge that I thought it was 1999. And when I got
17 my records from Mar-a-Lago I was able to find out
18 that it was 2000. And this was entered before I
19 found out the actual dates that I did work at
20 Mar-a-Lago.
21 Q (BY MS. MENNINGER) Okay. So a document
22 that you filed under oath --
23 A Um-hum.
24 Q -- is now, you believe to be untrue,
25 correct?
VIRGINIA GIUFFRE 5/3/2016 27
Agren Blando Court Reporting & Video, Inc.
1 another prince, the large hotel chain owner and
2 Marvin Minsky, is there anyone else that Ghislaine
3 Maxwell directed you to go have sex with?
4 A I am definitely sure there is. But can I
5 remember everybody's name? No.
6 Q Okay. Can you remember anything else
7 about them?
8 A Look, I've given you what I know right
9 now. I'm sorry. This is very hard for me and very
10 frustrating to have to go over this. I don't -- I
11 don't recall all of the people. There was a large
12 amount of people that I was sent to.
13 Q Do you have any notes of all these people
14 that you were sent to?
15 A No, I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this shit.
21 Q Did you have lawyers who were representing
22 you at the time you built a bonfire and burned these
23 notes?
24 A I've been represented for a long time, but
25 it was not under the instruction of my lawyers to do
VIRGINIA GIUFFRE 5/3/2016 205
Agren Blando Court Reporting & Video, Inc.
1 this. My husband and I were pretty spiritual people
2 and we believed that these memories were worth
3 burning.
4 Q So you burned notes of the men with whom
5 you had sex while you were represented by counsel in
6 litigation, correct?
7 MR. EDWARDS: Object to the form.
8 A This wasn't anything that was a public
9 document. This was my own private journal, and I
10 didn't want it anymore. So we burned it.
11 Q (BY MS. MENNINGER) When did you write
12 that journal?
13 A Just over time. I started writing it
14 probably in, I don't know, I can't speculate, 2012,
15 2011.
16 Q So you did not write this journal at the
17 time it happened?
18 A No.
19 Q You started writing this journal
20 approximately a decade after you claim you finished
21 being sexually trafficked, correct?
22 A Yes.
23 Q And you started writing a journal after
24 you had a lawyer, correct?
25 A Correct.
VIRGINIA GIUFFRE 5/3/2016 206
Agren Blando Court Reporting & Video, Inc.
1 Q Including Mr. Edwards, who is sitting
2 right here, correct?
3 A Correct.
4 Q What did that journal look like?
5 A It was green.
6 Q And what else?
7 A It was just a spiral notebook.
8 Q Okay. And what did you put into that
9 green spiral notebook?
10 A Bad memories. Things that I've gone
11 through, lots of things, you know. I can't tell you.
12 There was a lot of pages. It was over 300 pages in
13 that book.
14 Q Did you ever show that book to your
15 lawyers?
16 A No.
17 Q Did you show that book to anyone?
18 A My husband.
19 Q Did you show it to anyone else besides
20 your husband?
21 A No.
22 Q Did you tear out pages and give them to
23 Sharon Churcher?
24 A No, I wrote -- those pages that you're
25 talking about, I wrote for her specifically. She
VIRGINIA GIUFFRE 5/3/2016 207
Agren Blando Court Reporting & Video, Inc.
1 wanted to know about the Prince Andrew incident.
2 Q So that's a different piece of paper?
3 A Yeah, that's just random paper.
4 Q So you had a green spiral notebook that
5 you began sometime in 2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10 Q And do you have no other names of people
11 to whom you claim Ghislaine Maxwell directed you to
12 have sex, correct?
13 A At this time, no.
14 Q Is there any document that would refresh
15 your recollection that you could look at?
16 A If you have a document you'd like to show
17 me, I would be glad to look at it and tell you the
18 names I recognize off of that.
19 Q I'm just asking you if there's a document
20 you know of that has this list of names in it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it. It's not in my
VIRGINIA GIUFFRE 5/3/2016 208
DataSet-10
Unknown
1 pages
From: Darren Indyke ca.
To: Lesley Groff <1
Subject: Fwd: JE Deposition Corrections
Date: Thu, 19 May 2011 15:06:42 +0000
Attachments: Epsteindepo.PDF; 1558172_1.DOC
Darren K. Indyke
Darren K. Indyke, PLLC
301 East 66th Street, 10B
New York. New York 10065
Telephone
Direct:
Fax:
email:
************ ******** ********** ************* *********************** ***************** ***********
The information contained in this communication is confidential, may be attorney-client
privileged, and is intended only for the use of the addressee. It is the property of
Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication
or any part thereof is strictly prohibited and may be unlawful. If you have received this
communication in error, please notify us immediately by return e-mail, and destroy this
communication and all copies thereof, including all attachments.
Copyright of Darren K. Indyke, PLLC - 2011 Darren K.
Indyke, PLLC —All rights reserved.
********************************************* ******* *ISM*** **********************************
Begin forwarded message:
From: "Harry Susman" < S
Date: May 18, 2011 1:06:07 PM EDT
To: "Bill Dunseth" , "Darren Indyke" c>, "Harry
Susman" < , "Jeff Epstein" , "Jill
McCrary" < , "Jonathan J. Ross"
"Seth Ard" , "Steve Susman"
Subject: JE Deposition Corrections
See the attached memo and a copy of your deposition.
EFTA00433641
DataSet-10
Unknown
1 pages
Nen& 0 OP
FORT LAUDERDALE
Judge says he will approve
deposition by Ponzi figure
suits seeking to
to Convicted Investment comes a year and half after the than two dozen s of dollars
fraud scheme imploded, and with recover tens of million
scam operator Scott have alread y been filed, and the
a looming deadline to file bank-
Rothstein soon could be deadli ne for filing such
facing a lengthy ruptcy clawback claims against two-year Novem ber.
claims expire s in early
interrogation under oath. those who profited. s of the
Rothst ein, 48, is locked up ill an Attorn eys for victim
at ques-
BY PETER FRANCESCHINA undisclosed location, after help- fraud also want a crack judge
agents arrest a repute d tioning Rothst ein, but the
Sun Sentinel ing federal
eys temporarily denied a motion by
Ponzi schemer Scott Rothstein, Sicilian mobster. The attorn Roth- attorney Bill Scherer - who repre-
tions are that
the maestro who orchestrated said all indica
protection sents investors who allegedly lost
Florida's largest investment stein is in the witness another more than $100 million - to put
under
fraud, may soon be sitting down program, possibly
would likely take Rothstein under oath. The judge,
across from a phalanx of lawyers name, and that it
with feder- however, instructed Scherer to
to face a lengthy grilling under weeks of negotiations U.S. Bu- refile the motion under different
oath. al prosec utors and the
him bankruptcy rules and indicated
No one knows what Rothstein reau of Prisons to make he would then approve it
might want to say, or whether he available.
would invoke his Fifth Amend- Federal prosecutors could ob- LENGTHY TESTIMONY
ment right agains t self-in crimin a- ject to Rothstein giving a deposi-
tion, the attorneys said, if his co- Ray said it could take a week to
tion, but a federal judge on Mon- put all the questions to Rothstein,
d to bring
day said he will give the go-ahead operation is still require
t other with different batches of attor-
for bank uptcy lawyers and attor- criminal charges agains e. neys seeking information for the
neys for Rothstein's bilked inves- suspects in the Ponzi schem roughly two dozen federal and
tors to take the locked-up fraud- The prosec utors won't comm ent,
and one attorney called them the state lawsuits spawned by the
ster's deposition. that was fraud. Conceivably, Rothstein
d gorilla "
If Rothstein wants any hope of "1,000-poun could sit for one long deposition
Monday.
freedom one day, it may be in his not in the courtroom Chuck or in separa te sessions.
Bankruptcy attorn ey
best interest to tell all Scherer told the judge he has
Lichtman, who would be first in
utors for a
ALREADY COOPERATING line to conduct Rothstein's depo- been talking to prosec tion
Rothstein year about Rothst ein's deposi
He already has been cooper- sition, said he believes credi- and still doesn' t know if they will
help
ating with federal agents and has a strong motive to fight it."Th ey just listen." he said.
prosecutors investigating his tors and investo rs.
have to seek
$1.4 billion fraud, and helping "I believe Scott would tell the The attorneys may l judge,
U.S. Bankr uptcy appro val of the federa
creditors and investors could also truth," he said. Cohn, who retains jurisdic-
who presid- James
go toward reducing his 50-year Judge Raymond Ray, g, told tion in Rothst ein's crimin al case.
ed over Monday's hearin
prison term. e Roth- At one point on Mond ay,
The move by attorneys repre- Lichtman he will approv bank- Scherer joked that a football sta-
so the
senting investors and those mar- stein's deposition glean infor- dium might be necessary to ac-
ys can
shalling assets for his defunct ruptcy attorne used to file ad- commodate all the lawyers who
Rothstein Rosenfeldt Adler law mation that will be
firm to put Rothstein under oath ditional clawba ck lawsui ts. More want to quiz Rothstein.
EFTA00611093
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From:
To: Jeffrey Epstein
Subject: Fwd: Deposition
Date: Sat, 16 Jan 2010 20:47:28 +0000
Begin forwarded message:
From: "Bruce Reinhart"
Date: January 16, 2010 2:35:08 PM EST
To: "
Subject: Deposition
Does February 9-11 work for you? I need to get back to Critton and the other side to confirm a new date.
Also, please tell Jeffrey that, despite repeated requests to Darren, I have not been paid since the end of
September. The amount currently owed is just under $40,000. I try not to bother him with this, but I have
nowhere else to turn at this point.
Bruce E. Reinhart, P.A.
250 Australian Avenue South. Suite 1400
West Palm Beach. Florida 33401
www.BruceReinhartLaw.com
EFTA00667654
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13 pages
Timestamp: 4f202011 3:41:31 PM EST
EPSTEIN DEPOSITION NOTES 4.20.11
BILL SCHWARTZ
Wouldn't you always want a
shorter lockup? No. There are
reasons for longer lock ups
Only wanted to put in 2-year
max money. Understood it
would be a single lockup of a
single cap acct. Got this from
GD at time he first invested.
Never spoke to DZ until years
later. My understanding came
from counsel also. Everyone
knows I don't invest for more
than 2 yrs in a HF—too risky.
Doesn't recall whether he had
made other HF investments
that had sep lockups for
different traunches. Only
remembers the lockup terms on
this one because it is the only
one we've had a problem with.
Got letter in early 05 about
lockup rights of new and
existing investments. Also
spoke to GD in late 04 about
this. I've had many
conversations where I have
1
EFTA01102264
Timestamp: 4f202011 3:41:31 PM EST
warned against having more
than a 2 yr lockup. Should be
less.
X-1 (1/11/05 letter). Discussed
it with GD. Assured that this
letter accomplished a 2-year
lockup for entire cap acct.
Have always had one cap acct.
The letter didn't change this.
Letter reconfirmed that my cap
acct would not be subject to
3year lockup, but only 2 year
lockup. Doesn't recall whether
the lockup would end 2 years
from date of orig inv or from
another date.
Under orig. lockup, could
withdraw cap acct in June 04,
June 06 and June 08. Letter
said I could withdraw at end of
March 07. I did commit to
keep my money in the fund for
an additional 9 months. I
didn't think about it at the time.
I have a single cap acct, with a
single lockup period of 2 years,
starting from scratch in Jan. 05.
X-2. Memo from DZ to LPs in
2
EFTA01102265
Timestamp: 4f202011 3:41:31 PM EST
DBZ Spec. Opps Fund: only
new investments would be
subject to 3 year lockup.
FTC was set up when I left
Bear Stearns. Less than 30
people work for it. It is located
in the V. Islands. JE is resident
of VI. JE moved to NY in late
90s. FTC advises wealthy
individuals on investments and
does business only in the VI.
Investment in HZ Fund was my
own money. No clients
number. I have invested
clients money and my money
in other HFs (around 10)
Pled guilty to two counts:
solicitation of prostitution and
procuring a minor for
prostitution. Sentenced to 30
months: 18 in incarceration
and one year in community
control. From July 08-09 was
incarcerated; then in
community control (an intense
form of probation).
Met GD 18 years ago. He was
the fiancée of Eva Anderson, a
3
EFTA01102266
Timestamp: 4f202011 3:41:31 PM EST
former girlfriend. Became
friends in 2000. GD has given
me business advice; in 2002
became a good friend. Began
investing with him in 2000 and
r/s became more personal in
02. Became "godfather" of the
daughter. 16, 14 and 12 year
old kids.
Bet 2000 and today have
invested $300m with GD in
HB. HB=fund of funds. One
of HB's funds or divisions was
HG/Zwirn. GD thought I
should give DZ some money.
Gave Z money based solely on
D's recommendation. Didn't
meet Z til several years later.
I met Z only once in person,
for 5 minutes in my office.
Hadn't spoken to him before
then.
In 03 considered buying HB
myself. I went to JPM to see if
they would finance my
purchase, but I then decided
that JV made more sense.
Staley met with GD. Henry S
and GD each owned 50% of
4
EFTA01102267
Timestamp: 4f202011 3:41:31 PM EST
HB. I ended up getting $20m.
$15m given to FTC; $5m
given to people at Financial
Strategy. The people there
work only for me. I would
have had to pay their expenses
otherwise. Financial Strategy
provides legal and acctg
services. They are in NY.
Have less than 10 employees.
DI is in charge.
Doesn't know how much JPM
paid for HB. I think it paid
north of a billion. It had assets
of 4-7B under management at
the time. I was willing to pay
$2.5-3B.
GD came to JE's house and
said you should get a fee. JE
said pay me what is fair; I will
not negotiate. This was after
JPM had reached agreement
with GD. He said $20m. It
was essentially a finders fee.
X-3 is 12/28.04 invoice for
$15m for merger and acq
advice.
X-4 is proposed consulting
agreement bet FTC and HB of
5
EFTA01102268
Timestamp: 4f202011 3:41:31 PM EST
6/24/05: don't know what this
is about. We discussed
possible consulting but nothing
ever came of it.
Decision to invest in H/Z was
based solely on what D told
me. He said to put it with Z.
Same true for all 3 investments
in 02. Based solely on what D
advised. In 03, D probably
said they were doing very well;
I learned at some time it was a
pipe investor, i.e., making
bridge loans. Returns were
solid; had HB's money under
management (500-600m).
Wide-range of investment
opportunities.
Long speech about what GD
told JE after the redemption
request
Late Sept 06= call from DZ.
Said he was calling me to tell
me he was firing CFO, but
reasons for firing him were
immaterial. I asked what those
reasons were. He said, sorry, I
can't. He said it was on advice
of counsel. I said since it's the
6
EFTA01102269
Timestamp: 4f202011 3:41:31 PM EST
fund's counsel, I have a right to
know. I want all my money
out now.
I then called GD. I told him
about the call. I told GD I
want my money out. This is
nuts. He said relax, relax; let
me find out what's going on
He called me back 20 minutes
later and said Z will call you
tomorrow.
The next day Z did not call; I
think I call D around noon: Z
has not called me. D said it
will happen; I'll get right back
to you
45 minutes later Z called: I
understand ur upset, let me
explain what's happening.
There have been acctg irregs
and I had to fire my CFO; the
amt of money is less than 100k,
a couple of basis points; just
journal entry errors,
bookkeeping inaccuracies. At
first smell of trouble, my
discipline is to get my money
out. I said, I want to speak to
7
EFTA01102270
Timestamp: 4f202011 3:41:31 PM EST
the atty.
Spoke to GD right away and
told him what Z had said.
I spoke to DI and may have
spoken to HB about this
HD called me. He said I'm
calling to straighten out the
idea. DZ told you what was
immaterial at my direction.
We don't really know full
extent of what's going on. So
you told Z to lie to me. "I
represent all the limited
partners".
I then called GD. This is
ridiculous; I want all my
money out; I can't have
someone I distrust managing
money for me. I'm not being
told the full story
GD called back and said that
DZ understood that I wanted
all my money and that if I
asked for it, it would cause a
run on the bank. I talked to DZ
and he asked if I could reduce
my demand to half. I said no, I
want more than that. If HB is
8
EFTA01102271
Timestamp: 4f202011 3:41:31 PM EST
staying in I will leave my in. I
spoke to DZ and he agreed to
the $80m.
He called me back with DZ on
the phone and Z agreed to the
$80m. Z thanked me for
reducing my demand. He said
it would avoid run on bank.
We can set up a meeting with
the accountants to show them
and assure you that the $53m is
safe. BEFORE P. 42
Some cony with Z where he
said moneys were improperly
moved from offshore fund to
onshore fund; there was going
to be some adjustment of
interest; involved some journal
entries. Lots of questions from
the investor call transcript that
JE doesn't recall Z having told
him.
Recalls a conversation with HB
where I asked him to find out
how long it would take to get
other money's out. Doesn't
recall HB getting back to him
No follow up to demand for
9
EFTA01102272
Timestamp: 4f202011 3:41:31 PM EST
$80m. I thought I would get it
out around March because it
takes time to liquidate a HF
acct.
No cony. With DZ between
time he agreed to return $80m
and end of year
Jeepers set up a US sub of FTC
to avoid US-sourced income
via the fund investment.
Schwartz suggests that JE
agreed to withdraw his $80m
withdrawal demand in
exchange for the fund's
consent to the assignment
X-6 (executed
Assignment,12/29/06)
Didn't learn in Jan 07 that D
had informed Z that he was to
no longer manage HB money.
I didn't know about this; I was
surprised; he had told me he
was going to keep his money
in, but here he is pulling it out.
X-8 email of 2/14 from GD to
JE, with attached redemption
chart. Doesn't recall seeing
10
EFTA01102273
Timestamp: 4f202011 3:41:31 PM EST
this. He did send X-9. The
"conflicting conversations"
were about how much money
was in my acct, bet $127 and
$134m.
X-10 2/14/07 Letter
demanding withdrawal
No recall of conversation with ?
D, D's wife and Z
Has had 15-20 conversations
with GD about this matter
D said that Z was liar and
cheat; it's amazing that the
SEC found no violation; he
misled everyone; he was a
micro-manager. Nothing Z had
told him turned out to be
accurate.
In last 2 months I have had a
cony with Perry Gruss. He
agreed to meet with me. We
met for 5 minutes. The fund
had no liquidity; there was not
going to be a run on the bank;
it deferred fees to benefit Z's
personal tax position.
Who is Ron Tutor? ?
11
EFTA01102274
Timestamp: 4f202011 3:41:31 PM EST
D and my memories jogged on
the conversation we had with Z
together about him honoring
my $80m request
GD said he was misled by Z
about: (1) the airplane, (2) a
monstrous cash shortage and
the fund was totally illiquid,
(3) badly managed fund; (4)
no fear of run on the bank; (5)
things were immaterial when
they were material; (6) money
was taken from the H managed
account.
The fact that some of the funds
assets are illiquid doesn't mean
that the funds as a whole has
no money to redeem investors.
I asked D if he would provide
us an affidavit. X-12 is a draft
of affidavit that Lesley Groff
sent to GD to sign. I didn't ask
her to send it. I don't think I
read it before GD signed it. I
could have seen it.
GD said he would have
withdrawn H's money if he had
known about the airplane. In
12
EFTA01102275
Timestamp: 4/202011 3:41:31 PM EST
Oct or Nov. of 06, he said he
was keeping HB's money in
the fund.
13
EFTA01102276
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To:
From:
Subject: Re: Jeffrey Epstein
I just finished my deposition and am running late for a dinner. Please let me
know what time tomorrow will work. I can be available around noon as that is 9am
california time. My flight leaves around noon so i have some time in the morning.
Thanks.
EFTA_R1_00490530
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Nen& 0 OP
FORT LAUDERDALE
Judge says he will approve
deposition by Ponzi figure
suits seeking to
to Convicted Investment comes a year and half after the than two dozen s of dollars
fraud scheme imploded, and with recover tens of million
scam operator Scott have alread y been filed, and the
a looming deadline to file bank-
Rothstein soon could be deadli ne for filing such
facing a lengthy ruptcy clawback claims against two-year Novem ber.
claims expire s in early
interrogation under oath. those who profited. s of the
Rothst ein, 48, is locked up ill an Attorn eys for victim
at ques-
BY PETER FRANCESCHINA undisclosed location, after help- fraud also want a crack judge
agents arrest a repute d tioning Rothst ein, but the
Sun Sentinel ing federal
eys temporarily denied a motion by
Ponzi schemer Scott Rothstein, Sicilian mobster. The attorn Roth- attorney Bill Scherer - who repre-
tions are that
the maestro who orchestrated said all indica
protection sents investors who allegedly lost
Florida's largest investment stein is in the witness another more than $100 million - to put
under
fraud, may soon be sitting down program, possibly
would likely take Rothstein under oath. The judge,
across from a phalanx of lawyers name, and that it
with feder- however, instructed Scherer to
to face a lengthy grilling under weeks of negotiations U.S. Bu- refile the motion under different
oath. al prosec utors and the
him bankruptcy rules and indicated
No one knows what Rothstein reau of Prisons to make he would then approve it
might want to say, or whether he available.
would invoke his Fifth Amend- Federal prosecutors could ob- LENGTHY TESTIMONY
ment right agains t self-in crimin a- ject to Rothstein giving a deposi-
tion, the attorneys said, if his co- Ray said it could take a week to
tion, but a federal judge on Mon- put all the questions to Rothstein,
d to bring
day said he will give the go-ahead operation is still require
t other with different batches of attor-
for bank uptcy lawyers and attor- criminal charges agains e. neys seeking information for the
neys for Rothstein's bilked inves- suspects in the Ponzi schem roughly two dozen federal and
tors to take the locked-up fraud- The prosec utors won't comm ent,
and one attorney called them the state lawsuits spawned by the
ster's deposition. that was fraud. Conceivably, Rothstein
d gorilla "
If Rothstein wants any hope of "1,000-poun could sit for one long deposition
Monday.
freedom one day, it may be in his not in the courtroom Chuck or in separa te sessions.
Bankruptcy attorn ey
best interest to tell all Scherer told the judge he has
Lichtman, who would be first in
utors for a
ALREADY COOPERATING line to conduct Rothstein's depo- been talking to prosec tion
Rothstein year about Rothst ein's deposi
He already has been cooper- sition, said he believes credi- and still doesn' t know if they will
help
ating with federal agents and has a strong motive to fight it."Th ey just listen." he said.
prosecutors investigating his tors and investo rs.
have to seek
$1.4 billion fraud, and helping "I believe Scott would tell the The attorneys may l judge,
U.S. Bankr uptcy appro val of the federa
creditors and investors could also truth," he said. Cohn, who retains jurisdic-
who presid- James
go toward reducing his 50-year Judge Raymond Ray, g, told tion in Rothst ein's crimin al case.
ed over Monday's hearin
prison term. e Roth- At one point on Mond ay,
The move by attorneys repre- Lichtman he will approv bank- Scherer joked that a football sta-
so the
senting investors and those mar- stein's deposition glean infor- dium might be necessary to ac-
ys can
shalling assets for his defunct ruptcy attorne used to file ad- commodate all the lawyers who
Rothstein Rosenfeldt Adler law mation that will be
firm to put Rothstein under oath ditional clawba ck lawsui ts. More want to quiz Rothstein.
EFTA00683256
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From: "story cowles"
To: "Jeffrey Epstein"
Subject: Depositions
Date: Thu, 15 Oct 2009 14:58:56 +0000
I just spoke to Jessica regarding= and She told me that Brad's office has basically told Jessica that
no matter when she sets their deposition dates they will file protective orders. Jessica may just set their dates but
they will file protective orders. Jessica is also thinking about asking for dates to subpoena thLgafamily.
There is a hearing on November 3rd to get an answer as to how much longer we can depose After the
3rd we will be able to set depo.
Story
EFTA00771451
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From: Darren Indyke AOL -MIla>
To: Lesley Groff -MIMIlle
Subject: Re: Deposition Wed Nov 28?
Date: Fri, 23 Nov 2018 22:02:14 +0000
But we will make sure you are ready either way. III in town so I have u covered.
Sent from my iPhone. Please excuse the typos.
> On Nov 23, 2018, at 4:59 PM, Darren Indyke AOL < > wrote:
>
> Still possible that there will be a depo but possible no. In negotiations on case. I will
update you Monday if that is ok.
>
> Sent from my iPhone. Please excuse the typos.
>
>> On Nov 23, 2018, at 2:58 PM, Lesley Groff ‹ > wrote:
>>
>> Do we know if I go for a deposition on Wed Nov 28? I was asked to set this date aside but
have not heard anything in awhile.
>>
>> Sent from my iPhone
>
EFTA00485078
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1 pages
From: "story cowles"
To: "jeevacation®gmail.com" leevacation®gmail.com>
Subject: Depositions
Date: Wed, 15 Apr 2009 18:38:24 +0000
I spoke to Sandy (David Spicers paralegal) who informed me that they need a signed
"Stipulation for Substitution of Counsel" which I have here waiting for you to sign. They
will take care of the deposition scheduled for tomorrow. The next one is scheduled for next
Thursday the 23rd and then another the following Thursday the 30th.
Story
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Page 13 of 32
It read: "During a deposition given by me in connection with my matrimonial case, I stated that my husband had raped me.
"I wish to say that on one occasion during 1989, Mr Trump and I had marital relations in which he behaved very differently toward me
than he had during our marriage.
"Asa woman, I felt violated, as the love and tenderness which he normally exhibited toward me, was absent. I referred to this as a
'rape. but I do not want my words to be interpreted in a literal or criminal sense.
"My contrary conclusion would be an incorrect and most unfortunate interpretation of my statement which I do not want to be
interpreted in a speculative fashion and I do not want the press or media to misconstrue any of the facts set forth above.
"Al I wish is for this matter to be put to rest"
LOAD-DATE: April 28. 2016
LANGUAGE: ENGLISH
PUBLICATION-TYPE: Newspaper. Web Publication
JOURNAL-CODE: WEBDMI
Copyright 2016 Tnnity Mirror, Plc.
All Rights Reserved
Return to List
Note: Does not relate to money laundenng or terrorist financing.
FOCUS - 6 of 19 Documents
The New York Times
January 7, 2015 Wednesday
Late Edition - Final
Lawyer Denies Suit's Allegations of Sex With a Minor
BYLINE: By TIMOTHY WILLIAMS
SECTION: Section A. Column 0. National Desk. Pg. 13
LENGTH: 591 words
A well-known criminal defense lawyer, who along with Prince Andrew has been accused of having sex with an under-age girt has
denied the allegations in a federal court filing and asked that his name be removed from the case.
In court papers filed Monday in the Southern District of Florida, representatives for the lawyer, Alan M. Dershowitz, called the claims
that he had sex with a minor "outrageous and impertinent"
The accusations against Mr. Dershowitz. a professor emeritus at Harvard Law School. and Prince Andrew. second son of Queen
Elizabeth and fifth in line to the British throne, came in a motion filed Dec. 30 as part of a broader, long-running federal lawsuit. Mr.
Dershowitz and Prince Andrew are not parties to the broader lawsuit.
The motion claimed that Jeffrey E. Epstein, a wealthy businessman who has previously pleaded guilty to soliciting prostitution, had
forced the girl, beginning at age 15. to have sex with "politically connected and financially powerful people? including Mr. Dershowitz
and Prince Andrew. Buckingham Palace has vehemently denied the allegations against the prince.
The woman, who was not identified in the court document was repeatedly sexually abused by Mr. Epstein as a minor, the filing said,
and was "required" to have sex with Prince Andrew and Mr. Dershowitz several times. including in Florida, New York, New Mexico and
the Virgin Islands and on private planes.
https://www.lexisnexis.com/dd/delivery/PmtDoc.do?jobHandle=1825:640721064&dnldFil... 4/30/2018
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0059852
CONFIDENTIAL SDNY GM_00206036
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From: Lesley Groff
To: Jefffrey Epstein
Subject: possible deposition for me
Date: Fri, 31 Aug 2018 16:29:29 +0000
FYI-Justin Chu with Steptoe has asked me to hold Oct 10 and Oct 11 for possible dates for my
deposition in the case.
EFTA00480824
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From: Jeevacation < "eevacation©gmail.com > Subject: Re: Friday Deposition (Wild) To:'
Received: Monday, March 29, 2010, 10:47 AM Yes Sent from my iPhone On Mar 29, 2010, at
10:44 AM, wrote: Would you like me to set up video feed at
FSF for s deposition this coming Friday at 9am?
The information contained in this communication is
EFTA_R1_00540094
EFTA02030417