EFTA00761943.pdf
From: "story cowles"
To: "Jeffrey Epstein"
Found 1,000 results
in 62ms
EFTA00485077.pdf
From: Darren Indyke AOL -MIla> To: Lesley Groff -MIMIlle Subject: Re: Deposition Wed Nov 28? Date: Fri, 23 Nov 2018 21:59:19 +0000 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 EFTA00485077
EFTA00589581.pdf
TO: MARTY WEINBERG FROM: KIM HOMAN RE: EPSTEIN/DEPOSITION SUBPOENA DATE: APRIL 8, 2016 Under Fed. R. Civ. P. 45(c)(1)(A), a subpoena may compel a person to appear for a deposition only "within 100 miles of where the person resides, is employed, or regularly transacts business in person." A district court may quash or modify a subpoena that "requires a person to comply beyond the geographical limits specified in Rule 45(c)." Rule 45(d)(3)(A)(ii). Unfortunately, there is no easy answer to the question of how to determine where a person resides for purposes of Rule 45 or what "transacts business" means. I note at the outset that courts have generally placed the burden on the person moving to quash the subpoena to demonstrate that he falls outside the 100-mile limit. See, e.g., In re Application of Yukos Hydrocarbons Investments Ltd., 2009 WL 5216951 at *4 (N.D.N.Y. Dec. 30, 2009); RIMSTAT, Ltd. v. Hilliard, 207 B.R. 964, 969 (D.D.C. 1997); Regents of Univ. of California v. Kohne, 166 F.R.D. 463, 465 (S.D. Cal. 1996). I. RESIDENCE. I have only found one case which addresses the question of what "reside" means for purposes of Rule 45. In Yukos Hydrocarbons, the court first noted that "Rule 45(c)(3)(A)(ii) does not shed light on the intended meaning of the term "resides", and . . .there is a lack of authority providing any useful guidance." 2009 WL 5216951 at *5. The meaning of the term, the court continued, varies according to the context. Id. The court looked to New York law, which distinguishes residence from domicile, with the latter requiring "[e]stablishment of . . . a physical presence in the State and an intention to make the State a permanent home." Id., quoting Antone v. General Motors Corp., 64 N.Y.2d 20, 28 (1984). Under New York law, therefore, residence means something less than a permanent home. According to Yukos Hydrocarbons, "[t]he test for determining `residence' often employed by New York courts . . . turns on `whether [the individual] has a significant connection with some locality in the State as a result of living there for EFTA00589581 some length of time during the course of the year."' Id ., quoting Antone, 64 N.Y.2d at 30. That being the case, the court continued, one court held that a temporary residence frequented by a litigant for business purposes on only occasional overnight visits throughout the year did not qualify as a residence. See Hammerman v. Louis Watch Co., 7 A.D.2d 817 (3d Dep't 1958). Similarly, another court found the fact that a woman had visited a locale and rented a room, voicing an intent to remain, was insufficient to show that she had established a residence in New York, separate from her home in another location. See Siegfried v. Siegfried, 92 A.D.2d 916 (2d Dep't 1983) ("Although a person may have more than one residence for venue purposes, `to consider a place as such he [or she] must stay there for some time and have the bona fide intent to retain the place as a residence for some length of time and with some degree of permanency.' ") (internal citations omitted). Id. The court went on to hold that an individual who owned property in New York, and was registered to vote there, but had lived and worked in Russia for ten years and had only been in New York for a few months before returning to live and work in Russia did not reside in New York for purposes of Rule 45. It is my understanding that JE's primary and permanent residence is in the Virgin Islands but that he regularly spends time living in a home over which he has dominion and control in New York and that he has sufficient contacts in New York that he is required to register as a sex offender in that state. Under these circumstances, I think it likely that, under the analysis of Yukos Hydrocarbons at least, a court could find that JE was a resident of New York for Rule 45 purposes. II. REGULARLY TRANSACTING BUSINESS IN PERSON. The case law has predominantly focused on the meaning of "regularly" rather than what it means to "transact business." Such cases have by and large required more than minimal contacts within the 100-mile limit. See, e.g., Perez v. Progenies Pharm., Inc., 2015 WL 4111551 at *2 (S.D.N.Y June 24, 2015)(occasional meetings did not suffice); M'Baye v. New Jersey Sports Prod., Inc., 246 F.R.D. 205, 207 (S.D.N.Y. 2007)(14-18 visits in two years did not suffice); Bostian v. Suhor Industries, Inc.,2007 WL 3005177,at *1 (N.D.Okla.2007) (twice a year not sufficient); In re Application for Order EFTA00589582 Quashing Deposition Subpoenas, No. M8-85, 2002 WL 1870084, at *3 (S.D.N.Y. Aug. 14, 2002)(four times in five years not sufficient); Regents of the University of California v. Kohne, 166 F.R.D. 463, 465 (S.D.Ca1.1996) (ten times in seven years did not suffice); Halliburton Energy Services, Inc. v. M-I, LLC, No. 06-53, 2006 WL 2663948, at *2 (S.D.Tex.2006) (business trips to Houston four times a year, staying approximately ten days each trip, for a period of ten years "clearly place[s a person] in the category of regularly transacting business in person"). I have not found any cases that discuss what it means to "transact business" for purposes of Rule 45. In other contexts, the term has been defined to mean "the practical everyday business or commercial concept of doing or carrying on business of any substantial character." C C P. Corp. v. Wynn Oil Co., 354 F. Supp. 1275, 1278 (N.D. Ill. 1973). It is my understanding that JE frequently has business meetings in New York. The frequency of those meetings will determine whether the court would find that he "regularly" conducts business. An open question is whether an argument can be made, remembering that JE would have the burden of proof, that those meetings did not constitute transacting business. 3 EFTA00589583
EFTA00735546.pdf
From: Jeffrey Epstein
EFTA00727196.pdf
Grnail - Epstein -Doe Its Cross-Notice of Taking Deposition D...
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Jeffrey Epstein
EFTA01126167.pdf
From: pradlevi Fdvrard‘ To: jessfoa carbvit• lamer aahnma Subject: RE: Deposition of EW Data: Monday, November 02, 2009 12:39:56 PM I am not sure right now that I have the ability to 'file anything. That would entail access to certain things I am not sure I will have access to for long. I will do my best, but under the circumstances, I am shocked that Bob said that. Any way ho will call me and reconsider his position? Bradley J. Edwards Partner Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 a -. facsimile From: Jessica Cadwell truant Sent: Monday, November 02,IMNI MI To: Jacqule Johnson Cc: Bradley J. Edwards Subject: RE: Deposition of EW I spoke to Bob and he wants your office to file a protective order. We do not intend to cancel. jamica eadarell, YRS' Certified Paralegal Florida Registered Paralegal BURMAN CRITTON LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite N400 West Palm Beach, FL 334 Tel: / Fax: Email: From: Jacqule Johnson (mallto Sent: Monday, November 02, 2009 12:14 PM To: Jessica Cadwell; Connie ZaguIrre Subject: Deposition of EW Due to certain circumstances at RRA - we have no choic But to cancel the deposition of EW this week. Jacqule Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeld) Adlor EFTA01126167 401 East Las Olas Blvd. Suite 1650 Fort Lauderdale. FL 33301 Tolophone Fax EFTA01126168 Horn: Went lolinron To: lect-a Cockrell* Connie Mingo*, Subject: Deposbon NEW Date, Monday, November 02,2009 12:14:47 PM Due to certain circumstances at RRA - we have no choic But to cancel the deposition of EW this week. Jacquie Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeld( Adler 401 East Las Olas Blvd. Suite 1650 Fort Lauderdale, FL 33301 Telo EFTA01126169
EFTA00214687.pdf
From: " To: ' Subject: RE: I am back from my depositions Date: Wed, 19 Dec 2007 18:54:47 +0000 Importance: Normal I would settle for a Blackberry. The AFPDs have them and it makes life so much easier! From: PM 50 Subject: RE: I am back from my depositions Thank you. just need a TOM TOM GPS on you. 0 ye From: Sent: nes ay, ecem er , :16 PM Acosta, Alex (USAFLS) Subject: I am back from my depositions You can reach me a hank you. EFTA00214687
EFTA00437046.pdf
From: Lesley Groff
EFTA00420105.pdf
From: Darren Indyke la> To: Lesley Groff •::1 Subject: Fwd: REPLY790-re JEE deposition-HSG Date: Thu, 09 Feb 2012 20:38:57 +0000 Attachments: REPLY790-re_JEE_deposition-HSG.pdf Inline-Images: image001.png; image002.png Please print. Thanks. Darren K. Indyke Darren K. Indyke. PLLC ******** **************** ** ***************** ** ******* ************** ********************* ******* 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. ********************************************* ******* ********* ****************************** **** Begin forwarded message: From: "Linda A. Roberts" c Date: February 9, 2012 3:23:30 PM EST To: "- ,11 < Cc: "Joseph L. Ackerman, Jr." "Helaine S. Goodner" Subject: REPLY790-re JEE deposition-HSG Mr. Indyke, Please find attached the draft Reply, which Joe is simultaneously reviewing. Thank you, Linda EFTA00420105 Linda A. Roberts LEGAL ASSISTANT TO JOSEPH L. ACKERMAN, JR. main xtenston direct fax **TAX MATTERS- IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. If you would like such advice, please contact us.*** ***Attention: The information contained in this E-mail message is attorney privileged and confidential information intended only for the use of the individual(s) named above. if the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly prohibited. If you have received this communication in error, please contact the sender by reply E-mail and destroy all copies of the original message. Thank you. EFTA00420106
EFTA00480840.pdf
From: Lesley Groff
To: Jeffrey Epstein
EFTA00485079.pdf
From: Lesley Groff
EFTA00485080.pdf
From: Lesley Groff
EFTA00437053.pdf
From:
To: "David A. Yarema"
Subject: Re: Deposition Transcripts
Date: Thu, 17 Mar 2011 18:52:13 +0000
tremendous— thanks so much!
On Mar 17, 2011, at 2:47 PM, David A. Yarema wrote:
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
EFTA00733279.pdf
From: Jeffrey Epstein
EFTA02044377.pdf
To: From: Sent: Wed 9/7/2016 12:06:50 AM Subject: jeffrey's deposition in FL on Friday... do you have the information on Jeffrey's deposition in FL this friday...where, when, etc? If not, can you get from Darren so I can put in Jeffrey's itinerary... EFTA_R1_00575824 EFTA02044377
EFTA00733277.pdf
From: Jeffrey Epstein
EFTA00774039.pdf
From: "Sandy Hughes" cza.
To: "M it
Cc: "JEFFREY EPSTEIN"
EFTA00437052.pdf
From: "David A. Yarema" To: <1 >, Subject: Deposition Transcripts Date: Thu, 17 Mar 2011 18:47:28 +0000 Importance: normal Priority: normal Attachments: Rodriguez,_Alfredon Continued_Depo_8-07-09_(Doe_2).pdf Inline-Images: bcic.gif 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 - rn t w Phone: I Fax: Dir ct: 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 this message is not the intended recipient, or the agent responsible to deliver it to the intended recipient, you are hereby notified that any review, dissemination, distribution or copying of this communication is prohibited. If this communications was received in error, please notify us by reply e-mail and delete the original message. EFTA00437052
EFTA01077318.pdf
1250 Broadway Suite 24O0 VERITEXT Natrona, Deposition & Litigation Services New York. NY 'loom SETTER IN EVERY CASE 200 Old Country Road Suite 58O Mineola, NY 11501 fa June 2, 2011 Cooley Godward Kronish LLP 1114 Avenue of the Americas New York, NY 10036 Attention: William Schwartz, Esq. Re: Fortress VRF I LLC v Jeepers, Inc. Deposition of Jeffrey Epstein Conducted on April 20, 2011 Dear Mr. Schwartz: • The deposition transcript has been reviewed by the witness. ❑ No corrections/changes were made. 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. [2:1 Other: Witness signature page and notary are affixed. If you have any questions, please contact our office at (800) 727-6396. Sinc Tiffs y oman CI t Services Veritext, LLC Cc: Stephen D. Susman, Esq.; Allan Arffa, Esq. EFTA01077318 Page 273 1 Epstein 2 are going off the record. The time is 4:34 3 p.m. This is the end of Tape Number 6. 4 (Time noted: 4:34 p.m.) 5 6 JEFFREY EP TEIN 7 8 Subscribed and sworn to before me 9 this 23 day of 2011. 10 11 12 HARRY I. BELIER Notary Pubic. State of New 13 No. 019E4d 53924 York Qualified in Rockland Count Commission Expires Feb. 1 y nj 14 7.20L,/ 15 16 17 18 19 20 21 22 23 24 25 VERITEXT REPORTING COMPANY 212-267-6868 www.veritext.com 516-608-2400 EFTA01077319 Page 277 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: April 20, 2011 6 DEPONENT: Jeffrey Epstein 7 PAGE/LINE(S)/ CHANGE REASON 8 / / 9 10 11 12 13 / (A ‘ACttL 14 / / / 15 / / / 16 _ / / / 17 / / / 18 / / / 19 / / / 20 21 JEFFRE TEIN 22 AVSSCRIBED AND SWORN TO BEF ORE ME THIS 2.3 DAY OF , 2011. 23 HARRY I. BELLER Notary Public. State of New York 24 No. 013E435:5924 Qualified in Rockland County.L„? Commission Expiras Feb. 17, 20 25 NOTARY PUBLIC DATE COMMISSION EXPIRES VER1TEXT REPORTING COMPANY 212-267-6868 www.veritext.com 516-608-2400 EFTA01077320 EPSTEIN ERRATA SHEET-EXHIBIT 1 Page/line Change Reason 168:8 This happened on February 13 or 14, 2007. Misheard the date in the question 168:15-21 I don't know. Answer was not 168:25 responsive See my testimony at page 170, lines 2-23 170:10 Mistake See answer to the next question Did not hear the last 260:9-11 part of the question See my testimony at page 20:2-18 Mistake 266:10 This topic did not come up until February 2007. See Mishe ard the date my testimony at Inge 264:12-17. in the question 266:20 I had made a decision to take out $80 million, but I was Mista ke getting worried about the remainder too. EFTA01077321
EFTA00480827.pdf
From: Lesley Groff
To: Jeffrey Epstein