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To: Jeevacation(jeevacation©gmail.com]
From: story cowles
Sent Mon 3/29/2010 3:52:311
Subject: Re: Friday Deposition
The weather has not allowed the electricians to start the work on the outdoor sconces today. I
thought that if you are at the FSF Friday watching the depo it would be a good day to
reschedule them?
--- On Mon, 3/29/10, Jeevacation tevacation@gmaitcom> wrote:
From: Jeevacation leevacation ail.com>
Subject: Re: Friday osition
To: "story cowles"
Date: Monday, March 29, 2010, 10:47 AM
Yes
Sent from my iPhone
On Mar 29, 2010, at 10:44 AM, story cowles e > wrote:
Would you like me to set up video feed at FSF for deposition this
coming Friday at 9am?
EFTA_R1_01497172
EFTA02427862
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
I
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, , will take the deposition of
Jean Luc Bruhel on Tuesday, September 22, 2009, at 10:00 a.m., at:
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this // day of August, 2009 to all those on the
attached Service List.
1
EFTA01154310
By:
cc: Esquire Court Reporters
EFTA01154311
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To: Jeffrey Epsteinfleevacationagmail.comj
From: story cowles
Sent Wed 10/7/2009 9:31:00 PM
Subject: Deposition schedule as of October 7th at 5:30pm
Deposition schedule:
Tomorrow - You at Jacks (10am)
10/13 - Dave Rogers (10am)
10/13 - Robert Roxburgh (2pm if they finish with Dave or 4pm)
10/13 - Bill Hammond (in Iraq)(will have to be rescheduled)
10/15 - Larry Visoski 10am
10/19-
10/19-
10/19 -Janusz
10/20
10/20 -eB Rt (10am
10/28 - Khalid Zahir Monroe aka Khalid Salaam ( 10am)
10/29
11/10
11/23 - Michael Reiter 10am
11/24 -
11/24 -
11/24 -
EFTA_R1_01511489
EFTA02438335
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From: "Acosta, Alex (USAFLS)"
To: '
Subject: RE: I am back from my depositions
Date: Wed, 19 Dec 2007 19:06:39 +0000
Importance: Normal
Wasn't there a letter in which Jay said we made a decision to proceed the same day as the WPB meeting? I'm
trying to list various factual errors, and as I recall, we did not make an on the spot decision but waited for the FBI to
confirm certain views.
From: (USAFLS)
Sent: Wednesday, December 19, 2007 12:16 PM
To: ); Acosta, Alex (USAFLS)
Subject: I am back from my depositions
You can reach me at Thank you.
A. Villafaiia
Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach, FL 33401
Phone
Fax
EFTA00214280
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DRAFT OF:
February 18, 2011
EPSTEIN
NAMES IN APPEARING IN VARIOUS DEPOSITIONS
FROM RUSSELL ADLER DEPO
Jack Simone "Hedge fund guy" (p. 127)
Gary Farmer RRA lawyer
Steve Lippman RRA Lawyer
Robert Buschel RRA Lawyer (Knowledgeable of Q-task )
Russell Mix CEO of Q-task
Frank Veilson Member of Board of Co-op, New York Apartment
Jacky Brauser Mother of Matt Brauser
Matt Brauser Dates R. Adler's daughter
George Levin Friend of Rothstein, billionaire
Frank Preve Works for George Levin
FROM FRIEDMAN, LOMBARDI LIST
(CONDRAD SHERER SCHEDULED BUT DIDN'T TAKE)
Albert Peet
Sterling Bank rep
Robert Kutayiak
Marcie Lippman
Andrew Barnett
Robert Buschel
FROM LEON BRAUSER DEPO
Michael Szafranski
Jim McCay
Larry Yogel
Alan Weinstein, investment broker
FROM BRADLEY EDWARDS DEPO
Maria Kelljian Paralegal
Beth Williamson Paralegal
Michael Fisten Investigator
Dean Howell Referred E.W. case against Epstein
Paul Cassell Appellate attorney from Utah
Ken Jenne Investigator, former Broward Sheriff
Bill Berger
Richard Fandry Investigator
Jane Muskrat Media rep (?)
Michelle Daryan Media rep (?)
Chislaine Maxwell
-1-
EFTA00600049
Michael Sanka Interviewed by Michael Fisten
Patrick Roberts Investigator
Nesbitt Kirkendahl FBI Agent
Jason Richards FBI Agent
Dexter Lee US Attorney
Maria Villafana
Mark Epstein
Judge Stone
Deborah Villegas Rothstein's right arm
Bart' Bekkadan
A.J. Discala
Alfredo Rodriguez (Deposed by Edwards) Claims he had list of names and addresses of
females who may have come to Mr. Epstein's house along with phone
numbers.
Michael Szafranski
Dominic Ponatchio
Moto Ban Mon
Shimone Levy
Obidia Levy
Daniel Minkowitz
George Levin Billionaire
Frank Preve Worked for Frank Preve
Bill Brock Relative of Rothstein's, worked at RRA
Dean Kretchmar
Doug Van Allman
Ted Morse
Ed Morse
Richard Pearson
Stevin Levin
Ira Sochet
Mark Melvin
Jack Samoney
Lawrence King
Steve Jackel
Michael Legamaro
Kevin Draber
David Boden
Andrew Barnett
Alan Sakowitz
Mark Nurik Represents Rothstein
Mark Fistos Edwards current partner
Tommy Mottola Former president of Sony Records
Officer Recarey Deposed
-2-
EFTA00600050
Chief Reiter Chief of Palm Beach Police Dept.
Bill Berger
Bill Scherer
Alfredo Garcia Pled guilty to obstruction of justice charges
(Edwards attempted to coordinate the depos of the following:)
David Copperfield (potential witness)
Bill Clinton Former president
Alan Dershowitz One of Epstein's lawyers
Donald Trump
Leslie Wexner
(ENTITIES FROM EDWARDS DEPO)
Blue Line Research Composed of Roberts, Fandrey, Fisten and Jenne
Clockwork Capital Advisors
Razorback Funding
Benozon
Onyx Capital
Onyx Options Consultants
BWS Investments
Pirulin Group
Fortress Investments or Fortress Capital
Drawbridge
Banyon Investments
Cetnurion Credit Fund
Platinum Management Fund
NAMES FROM S. APRILL MEMO DATED FEBRUARY 10, 2011
Discala Convinced several investors to invest in Rothstein
Chris Podaras Hampton Capital in New York - invested in Razorback
Thane Ritchie Operates a $4-5 million hedge fund
Michael Szafranski Engaged by Platinum and centurion Hedge Funds as alleged 3rdparty
verifier of the Rothstein investment.
Barry Bekkedam Owns Ballacor
Elizabeth Friedland Discala's secretary
Michael Legomaro
Ken Jenne
Mike Fisten
Saudi Prince
Bill Clinton
Naomi Campbell
Ted Waite Present girl friend was former girl friend of Epstein
-3-
EFTA00600051
Bill Hobbs In house counsel for Ritchie Capital
Meeting of Razorback and Clockwork Investors included:
John Antolikj
Chris Podaras
Jim Parrish
AJ Discala
Frank Preve
Michael Christ
Thane Ritchie
Barry Bekkedam
Al Rappetti
W:40743tN A /A ES APPEARING IN DEPOS. M EM OS, POSS DEPONENTS
-4-
EFTA00600052
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To: Jeffrey Epsteinfleevacation©gmail.com]
From: Matthew I. Menchel
Sent: Tue 2/1/2011 2:34:39 PM
Subject: RE: Re:
Unfortunately, no I've got a deposition that I'm taking in Florida on the 14'. I will be in New York on the
r (which I think I mentioned to you) but I am giving a lecture during lunchtime and then flying home
that evening. I could meet you for a late lunch on that day. Otherwise, I probably won't be back until
around mid•March.
Matthew I. Menchel
KOBRE & KIM LLP
w.vw.kobrekim.com
New York I London I Hong Kong I Washington DC I Miami
From: Jeffrey Epstein [mailto:jeevacation@gmail.com]
Sent: Tuesday, February 01, 2011 9:28 AM
To: Matthew I. Menchel
Subject: Re: Re:
can you do Florida the 13 di or 14th?
On Tuc, Fcb 1, 2011 at 9:27 AM, Matthew I. Mcnchcl
wrote:
Did you meant to write something? Thcrc is nothing in the response.
EFTA_R1_00212358
EFTA01833798
Matthew I. Menchel
KOBRE & KIM LLP
www.kobrckim.com
New York : London Hong Kong Washingion DC I Miami
From: Jeffrey Epstein [mailto:icekacationta cinail.com1
Sent: Tuesday, February 01, 2011 9:27 AM
To: Matthew I. Menchel
Subject: Re: Re;
On Tue, Feb 1, 2011 at 9:22 AM, Matthew I. Menchel
Wrote:
Jeffrey,
My flight to New York just got cancelled along with my Court appearance so I won't be in New
York tomorrow. My apologies but obviously out of my control. I'll let you know next time Pm
headed up that way or if you are in Florida we could always meet down here as well.
Best,
Matt
Matthew I. Menchel
KOBRE & KIM LLP
www.kobrckim.corn
New York I London I Hong Kong I Washington DC I Miami
Original Message
From: jeffrey epstein [maikojeevacationagmail.com]
EFTA_R1_00212359
EFTA01833799
Sent: Sunday, January 23, 2011 12:22 PM
To: Matthew I. Menchel
Subject: Re: Re:
Lunch , lord MANDELSON will join if ok with you
Sony for all the typos .Sent from my iPhone
On Jan 23, 2011, at 5:01 PM, "Matthew I. Menchel" •c >
wrote:
> Lunch or Dinner on the 2nd?
> Matthew I. Menchel
> KOBRE & KIM LLP
> wvvw.kobrekim.com
> New York I London I Hong Kong I Washington DC I Miami
> From: Jeffrey Epstein
> >
> Date: Sun, 23 Jan 2011 16:09:10 +0100
> To: Matthew Menchel
>
> Subject: Re: RE: Re:
> Any chance the week before? You would join interesting people?
> Sony for all the typos .Sent from my iPhone
> On Jan 23 2011 at 4:00 PM "Matthew I. Menchel"
mailto: >> wrote:
> How does a late lunch on the 8th work for you? Have to give a presentation during lunchtime
but could meet with you afterwards.
> Matthew I Menchel
> KOBRE & KIM LLP
> www.kohrekiin.cont
> Ncw York I London Hong Kong I Washington DC I Miami
EFTA_R1_00212360
EFTA01833800
> From: Jeffrey Epstein [mailto:jeevacation@gmail.com]
> Sent: Wednesday, January 19, 2011 12:32 PM
> To: Matthew I. Menchel
> Subject: Re:
> sometine that week . I thought you would come to dinner with woody alien this week, but i
will wait to see you that week.
> On Wed Jan 19 2011 at 7:29 AM Matthew I. Menchel
< In London doing an ICC arbitration. Should be back in NY February 2. Will you be around?
> Matthew I. Menchel
> KOBRE & KIM LLP
> www.kobrekim.corn
> New York I London I Hong Kong I Washington, DC I Miami
> From: Jeffrey Epstein
> [mailto:jeevacation®gmail.conailto:jee
> vacation@gmail.com>]
> Sent: Wednesday, January 19, 2011 06:50 AM
> To: Matthew I. Menchel
> Subject:
> are you in town
> --
>
> The information contained in this communication is confidential, may
> be attorney-client privileged, may constitute inside information, and
> is intended only for the use of the addressee. It is the property of
> Jeffrey Epstein Unauthorized use, disclosure or copying of this
> communication or any part thereof is strictly prohibited and may be
> unlawful. If you have received this communication in error, please
> notify us immediately by return e-mail or by e-mail to
>
> jeevacation@gmail.com, and destroy this
> communication and all copies thereof, including all attachments.
> copyright -all rights reserved
EFTA_R1_00212361
EFTA01833801
> This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged
and/or confidential information. If the reader of this message is not the intended recipient(s), or
the employee or agent responsible for delivering the message to the intended recipient(s), you are
hereby notified that any dissemination, distribution or copying of this e-mail message is strictly
prohibited. If you have received this message in error, please notify the sender immediately and
delete this e-mail message and any attachments from your computer without retaining a copy.
> IRS Circular 230 disclosure: Any tax advice contained in this
> communication (including any attachments or enclosures) 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 in this communication. (The foregoing disclaimer
> has been affixed pursuant to U.S. Treasury regulations governing tax
> practitioners.)
>
> ***********************************************************
> The information contained in this communication is confidential, may
> be attorney-client privileged, may constitute inside information, and
> is intended only for the use of the addressee. It is the property of
> Jeffrey Epstein Unauthorized use, disclosure or copying of this
> communication or any part thereof is strictly prohibited and may be
> unlawful. If you have received this communication in error, please
> notify us immediately by return e-mail or by e-mail to
>
> jeevacation@gmail.com, and destroy this
> communication and all copies thereof, including all attachments.
> copyright -all rights reserved
> This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged
and/or confidential information. If the reader of this message is not the intended recipient(s), or
the employee or agent responsible for delivering the message to the intended recipient(s), you are
hereby notified that any dissemination, distribution or copying of this e-mail message is strictly
prohibited. If you have received this message in error, please notify the sender immediately and
delete this c-mail message and any attachments from your computer without retaining a copy.
> IRS Circular 230 disclosure: Any tax advice contained in this
> communication (including any attachments or enclosures) 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)
EFTA_R1_00212362
EFTA01833802
> promoting, marketing or recommending to another party any transaction
> or matter addressed in this communication. (The foregoing disclaimer
> has been affixed pursuant to U.S. Treasury regulations governing tax
> practitioners.)
> This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged
and/or confidential information. If the reader of this message is not the intended recipient(s), or
the employee or agent responsible for delivering the message to the intended recipient(s), you are
hereby notified that any dissemination, distribution or copying of this e-mail message is strictly
prohibited. If you have received this message in error, please notify the sender immediately and
delete this e-mail message and any attachments from your computer without retaining a copy.
> IRS Circular 230 disclosure: Any tax advice contained in this
> communication (including any attachments or enclosures) 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 in this communication. (The foregoing disclaimer
> has been affixed pursuant to U.S. Treasury regulations governing tax
> practitioners.)
This e-mail message is from Kobre & Kim LLP, a law firm, and may contain legally privileged
and/or confidential information. If the reader of this message is not the intended recipient(s), or
the employee or agent responsible for delivering the message to the intended recipient(s), you arc
hereby notified that any dissemination, distribution or copying of this e-mail message is strictly
prohibited. If you have received this message in error, please notify the sender immediately and
delete this e-mail message and any attachments from your computer without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication (including any
attachments or enclosures) 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 in this communication. (The
foregoing disclaimer has been affixed pursuant to U.S. Treasury regulations governing tax
practitioners.)
******* ************************************ ****************
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
EFTA_R1_00212363
EFTA01833803
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@gmail.com and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
This e-mail message is from Kobre a Kim LLP, a law firm, and may contain legally
privileged and/or confidential information. If the reader of this message is not
the intended recipient(s), or the employee or agent responsible for delivering
the message to the intended recipient(s), you are hereby notified that any
dissemination, distribution or copying of this e-mail message is strictly
prohibited. If you have received this message in error, please notify the sender
immediately and delete this e-mail message and any attachments from your computer
without retaining a copy.
IRS Circular 230 disclosure: Any tax advice contained in this communication
(including any attachments or enclosures) 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 in this communication. (The foregoing disclaimer
has been affixed pursuant to U.S. Treasury regulations governing tax
practitioners.)
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jecvacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA_R1_00212364
EFTA01833804
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From:
To: "Spencer Kuvin"
Subject: B.B. v. Jeffrey Epstein
Date: Fri, 22 Jan 2010 19:55:26 +0000
Importance: Normal
Attachments: 20100122_Kuvin_Ltr_re_M_Deposition.pdf
Dear Mr. Kuvin — A response to your letter is attached.
Assistant U.S. Attorney
500 E. Broward Blvd, 7th Floor
Ft Lauderdale, FL 33394
EFTA00213309
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From: Brad Edwards
To: J
Subject: Re:
Date: Wed, 19 Dec 2018 12:54:53 +0000
I have to take a deposition early this morning. I can talk now if we still need to talk. I think everything is being
handled already for Sarah to sign.
Sent from my iPhone
On Dec 18, 2018, at 8:59 PM, J leevacation®gmail.com> wrote:
Time
On Tue, Dec 18, 2018 at 8:42 PM Brad Edwards c > wrote:
I can talk in the morning.
Sent from my iPhone
On Dec 18, 2018, at 8:01 PM, J wrote:
do you have minute to speak. re signatures no worry
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation®gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
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
EFTA01011524
return e-mail or by e-mail to jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA01011525
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DRAFT
Fowler WhiteATB
muNE,rSpmeLtAt,)p 4 18 11 8:21 PM
MEMORANDUM
TO: File
FROM: Susan H. Aprill
DATE: April 18, 2011
RE: Outline of deposition of Russell Adler, former RRA partner
FILE NO.: 80743
Epstein v. Rothstein & Edwards
Outline for Russell Adler Deposition, 4-20-11 @ 9:30 am
1. Introduction
1.1 Name
1.2 Home address; business address
1.3 Date of Birth
2. Instructions for deposition
2.1 Are you under any medications that would affect your memory or ability
to testify truthfully and accurately today
3. Notice of Taking Deposition and subpoena duces tecum
3.1 Have you ever seen this document?
3.2 Exhibit A: Did you bring the documents requested?
3.3 Review what he has/what he brought/what he could not bring because not
in his control
3.4
4. Education
4.1 college
EFTA00600180
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 2
4.2 law school
4.3
5. Employment
5.1 Current: How do you earn a living? Income
5.2 What are you currently doing/where employed?
5.3 Prior employment
5.4 from law school to present
5.5 at RRA
5.6 since RRA
5.7 Shortcut by referring to his earlier depo and that of Edwards:
5.8
6. Prior Depositions and lawsuits
6.1 Are you presently a party in a suit(s)?
6.2 Name(s)? which side?
6.3 Other than for professional negligence, ever a party in a suit before
November 2009?
6.3.1 Explain/describe/outcome?
6.3.2
6.4 Testimony in past
6.4.1 What type of case(s) were did you testify in?
6.4.2 In court as witness or party?
6.4.3 Have you ever been deposed? remind him he is under oath/perjury
6.4.3.1 How many times? [refer to last year depo]
6.4.3.2 have you read the transcript of the one in BR court?
6.4.3.3 any inaccuracies you recall?
EFTA00600181
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 3
6.4.3.4
6.4.3.5 As witness or party?
6.5 Read any transcripts in THIS CASE?
6.6 Do you know if anyone was deposed in THIS CASE?
6.7 Know BE was deposed? did you talk to him about fact that you were
subpoenaed?
6.8 Talk to BE counsel? Talk to anyone other than your own lawyer about fact
you were giving depo today or at all in this case?
6.9
7. RRA
7.1 When did you join RRA
7.2 confirm what he set in prior depo
7.3 how many lawyers then?
7.4 You are the A in RRA? What did that get you?
7.5 Departments? did you head any? which?
7.5.1 who else was in it during 2008-09?
7.5.2 What other lawyers did you work with in that time frame?
7.6 What is Q-task (Edwards tr. at 25);
7.7
8. Brad Edwards
8.1 know him?
8.2 since when?
8.3 ever work with him? explain.
8.4 he joined RRA in spring 2009?
8.5 how did that occur?
EFTA00600182
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 4
8.6 did you recruit him? If no, who did?
8.7 If yes, why?
8.8 what did BE have that made you recommend him to the firm?
8.9 was it his book of business? explain what he told you he had?
8.10 Other than his book, did he have something else that made him attractive
to the Firm/you?
8.11 Describe his negotiations with RRA; did you broker the deal?
8.12 Did BE have any other supporters at the firm who wanted him to join? IF
yes, who?
8.13 What did you know of his legal work, skills?
8.14 Ever work with him elsewhere? on a case together?
8.15 Were you two friends? (BE tr 64)
8.16 Ever see him outside of professional setting?
8.17 Ever see him in setting?
8.18 Knew him from the gym BE has testified. (Tr. 64)
8.18.1 BE said he worked out with you for 4-5 years (starts ca. 2004)
8.18.2 what gym?
8.18.3 go in the morning, evening, when?
8.18.4 ever get together after the gym?
8.18.5 ever do sports with him outside of gym, tennis, golf, any?
8.18.6 ever go to BE office?
8.18.7 Where was it?
8.19 Who initiated the idea that BE join RRA?
8.20 What was discussed and with whom about it?
8.21 Any email communications between you and BE about negotiations
BEFORE he joined?
EFTA00600183
April 18, 2011 DRAFT
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Page 5
8.22 How long in negotiations?
8.23 Did BE use a lawyer to rep him? Who?
8.24 email between you and anyone else about BE joining?
8.25 You talked to Scott R about him?
8.26 What did you say to Scott?
8.27 What did he say to you about BE?
8.28 What did BE ask for as compensation?
8.28.1 Do you recall what he was making at the time you started talking?
8.28.2 He must have shown you financials from his firm? What had he
earned in 2008, 2007 ever?
8.28.3
8.29 What process was followed to come up with a comp package to negotiate?
8.30 Who looked at his financials if not you?
8.31 What lawyer(s)?
8.32 What admin. persons?
8.33 The deal BE ACTUALLY got:
8.33.1 Did you offer him a job? [BE tr. 67, says he was asked by Russ
and then he met Scott]
8.33.2 Who made the decision at RRA? (Scott, you, a collaboration?)
8.33.3 What draw? recall amount/range?
8.33.4 bonuses for collections? successful results on cases?
8.33.5 Any formula? explain?
8.33.6 Did the firm have a standard formula for contingent fee bonuses?
8.33.7 Was BE's recovery deal like yours?
8.33.8 What was yours?
EFTA00600184
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Page 6
8.33.9 What perqs did BE get?
8.33.9.1 were they standard?
8.33.9.2 If not, what was exceptional?
8.33.10 How would you find out this information if you do not have it?
8.34 Financing BE contingent fee cases:
8.34.1 how was that done?
8.34.2 Did RRA pay all costs/expenses advanced on BE cases?
8.34.3 What about the costs he had advanced on cases he brought over?
8.34.4 BE testified that
8.35 Did BE bring anyone with him to RRA?
8.35.1 paralegals, clerks, associates, secy? explain
8.36 Any loans by RRA to BE?
9. Who worked with BE at RRA?
9.1 Go through lawyer names mentioned in priv log, including Buschel,
Stone, Bill Berger, Adler (go through does).
9.2
10. Others who may have worked with BE on cases:
10.1
11. Cara Holmes
11.1 who hired her?
11.2 to whom did she report?
11.3 Where did she work before?
11.4 She was a very new lawyer, inexperienced?
11.5 So why was she on these cases?
12. Other staffing?
EFTA00600185
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Page 7
12.1 Christina Kitterman?
12.1.1 What did she do?
12.1.2 what level of atty?
13.
14. JEE CASES
14.1 Did you ever work on any cases at RRA against a defendant named JE?
14.2 Starting when?
14.3 Did you know who JEE was prior to working on any case?
14.4 How?
14.5 What did you know of him at first? From what source?
14.6 Did you know BE had cases going against JEE before BE joined RRA?
14.7 How did you know this? [BE tr. 76: "doesn't recall" talkng to Russ about
them until after he joined)
14.8 Did BE bring active filed cases agst JEE to RRA when he joined?
14.9 Did you know Paul Cassell? If yes, since when and how did you meet?
14.10 A Mr. Howell? same as for Cassell.
14.11 3 files: State court was ■. (Jane Doe # 2), E.W. (Jane Doe #1) and .
14.12 Who staffed the Epstein files?
14.12.1 BE testified that you Judge Stone, Bill Berger and Rob Buschell
worked on cases? [BE tr. 229-232]
14.12.2, you, e.g., attended Mark Epstein's depo
14.12.3 you were to coordinate depos or be involved for all high profile
people?
15. Did Adler and others ever talk about Epstein case(s).
15.1 Who?
15.2 When?
EFTA00600186
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 8
15.3 How many cases or claims?
15.4 Did you meet with any of the Plaintiffs and/or their families to discuss
Epstein and the alleged claims against him?
15.4.1 If so, who did he meet with?
15.4.2 How many times did he meet with them?
15.4.3 Who else was present (i.e., RRA lawyers, paralegals, secretaries
and/or investigators)?
15.5 Did you ever tell anyone that RRA lawyers would sue Epstein and
disclose embarassing information about Epstein, his friends, family and associates if he did not
settle for a large sum of money?
15.6 Was this part of the "valuation strategy?"
15.7 How much did it cost RRA to litigate the Epstein cases?
15.8 Did you have to approve the costs?
15.9 Wasn't BE in your practice group?
15.10 You were responsible in some way? explain.
15.11 Are you still in any way connected to the suits brought against Epstein by
BE?
15.11.1 Do you own a share?
15.11.2 have any kind of deal?
15.12 Edwards testified that he spoke to you often (regularly) about the JE
cases? [BE tr. 125], true?
15.13 He testified that you and he spoke about the value of the Epstein cases and
also Bill Berger [BE tr. 292]
15.13.1 Recall such conversations?
15.13.2 Who said what to whom?
15.13.3 how many?
15.13.4 how did you value?
15.13.5 know about the Non-prosecution agreement concerning Epstein?
EFTA00600187
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 9
[IS ASKING RE NPA A PROBLEM?]
15.14 Edwards testified you and he and Scott had at least one conversation about
Epstein case (s). [BE tr. 117]
15.14.1 recall?
15.14.2 Who else was there?
15.14.3 REVIEW VARIOUS DOCUMENTS ABOUT THE CASES;
IF EYES ONLY, CANNOT SHOW BUT WORK IN FACTS GENERALLY IF
POSSIBLE.
15.14.4
16. When did Scott or RA determine JEE cases would be of interest to investors?
17. What did you tell Scott about JEE as a target or otherwise?
18. What deal did he offer Edwards to move there? How much money? Bonuses?
Explain
19. Involvement with Settlement Investments
19.1 D3 Capital CLub concerned Epstein alleged settlements?
19.2 Were you aware?
19.3 Did other lawyers in the firm (partners) know Scott Rothstein ran
investments?
19.4 Did lawyers at the firm know of the structured settlement business?
19.5 How could they not know?
19.6 Did Edwards know?
19.7 What did he know?
19.8 When did he know?
19.9 You are a PI lawyer, you know how structures work, right?
19.10 That's not how these worked?
19.11 Ever talk to BE about how JEE fit Scott's settlement model?
19.12 Who at the firm helped Scott create or operate the Epstein investments?
EFTA00600188
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 10
19.13 Did Villegas know about JEE deals?
19.14 Know Michael Szafranski (or of him)?
19.14.1 If yes, explain role of Szafranski regarding JEE cases?
19.14.2 He was an independent verifier, did he know him to do that?
19.14.3 what is that?
19.15 Do you know about Epstein flight logs?
19.15.1 How did you learn about them?
19.15.2 Are they authentic?
19.15.3 Have you seen them?
19.15.4 Were they the product of investigative team?
19.15.5 How found?
19.16 Explain purpose of Noticing depos of prominent (Clinton, Trump,
Dershowitz, etc.)
19.17 Were you aware of investors coming in and looking at Epstein files?
19.18 ever meet any?
19.19 Did Jenne or Fisten tell you they brought in files?
19.20 know Michael Legamaro? Hear of him? Who is he?
20. Does he know a
20.1 If so, did he ever talk to her, give her an interview, etc.?
21. Did he ever instruct RRA investigators to work on Epstein case?
21.1 If not, does he know if anyone (BE) did?
21.2 Does he know if they conducted surveillance on Epstein property?
21.3 Other types of investigation on JEE? If so, what?
21.4 What types of surveillance was conducted?
EFTA00600189
April 18, 2011 DRAFT
4 18 11 8:21 PM
Page 11
21.5 Did they have the details on Epstein's property? Did they have drawings
depicting the property? Did they have floor plans of the interior structures on Epstein's property?
21.6 How did they gain access to Epstein's property?
21.7 What information were the investigators asked to get from their
investigation and surveillance?
21.8 How may time did the investigators conduct surveillance on Epstein?
21.9 Do you know Wayne Black?
21.9.1 Who is he?
21.9.2 Who hired and authorized Wayne Black to investigate Epstein?
21.9.3 Did he conduct surveillance on JEE?
21.9.4 What did he do/function?
21.9.5 What types of investigation techniques were used to monitor
Epstein (wire taps, bugs, other listening and watching)?
21.9.6 What is Blue Line R & D?
21.10 Knowledge of skills and involvement of:
21.10.1 Mike Fisten
21.10.2 Ken Jenne
21.10.3 Patrick
21.10.4 Rick Fandry
22. Criminal History - have you ever been convicted of a crime? If yes, when and for
what?
C:WserAill0JAVIMApplkdatocallAticsosoll1Windowsffemporary Internet FilegeonlentOudaoMY0CEB88111OLITLNE47•Depostion DI Rumen Adler 4-20.11.
SA.docsj4/IVl11.11:2(1)
EFTA00600190
DataSet-10
Unknown
1 pages
From: "Chu, Justin" czMINI >
To: Lesley Groff
Subject: RE: v. Epstein, et al
Date: Wed, 29 Aug 2018 12:45:23 +0000
Lesley,
We are looking for potential deposition dates in late September and October. Would
you please let me know your availability? Thanks.
Justin
Original Message
From: Lesley Groff [mailto:
Sent: Wednesday, August 29, 2018 8:00 AM
To: Chu, Justin
Subject: Re: v. Epstein, et al
thank you
> On Aug 28, 2018, at 4:41 PM, Chu, Justin < > wrote:
•
> Lesley,
Please see attached Rule 26(a)(1) Disclosure Statement served today.
> Justin
>
EFTA00480614
DataSet-10
Unknown
2 pages
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR PALM BEACH COUNTY CIVIL DIVISION
CASE NO.: 502009CA040800 AG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, etc., et al.,
Defendant(s).
ORDER ON DEFENDANT/COUNTER-DEFENDANT'S
MOTION FOR PROTECTIVE ORDER IN REGARD TO THE DEPOSITION
DUCES TECUM OF RECORDS CUSTODIAN AND TRUSTEE HERBERT STETTIN
THIS CAUSE came before the Court upon the above Motion, the Court heard
argument of counsel and is fully advised in the premises. Based upon the foregoing, it is
CONSIDERED, ORDERED AND ADJUDGED as follows:
The Subpoena seeks all e-mail communication between various attorneys of
the former Rothstein firm and various governmental offices regarding JEFFREY EPSTEIN.
The request is not limited to time, subject matter or scope and, according to the
documents presented to this Court, could be in excess of 10,214 pages of e-mails. At this
point, the Court finds that the request is overbroad and not necessarily calculated to lead
to admissible evidence. The purported basis for obtaining these records is to establish
some type of "abuse of process" in regard to the non-prosecution agreement entered into
between the government and the Plaintiff. At present, there is no pending Complaint by
the Plaintiff which has withstood a Motion to Dismiss dealing with the issue of whether or
not some actions by the Defendant in regard to the non-prosecution agreement could
constitute "abuse of process". Therefore, the Defendant's Motion for Protective Order is
EFTA01114413
Epstein tr. Rothstein, et at.
Case No. 502009CA040800XXXJCMBAC
Order
Page 2
granted and the Objection to production of records is hereby granted, both without
prejudice.
DONE AND ORDERED this da;ofJuly 011 t VVeSt Palm Beach, Palm
Beach County, Florida. 11
DAVID F. CROW
CIRCUIT COURT JUDGE
Copy furnished:
JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409
JOSEPH L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 Phillips Point West, West Palm
Beach, FL 33401
JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401
MARC NURIK, ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301
GARY M. FARMER, JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301
MARTIN WEINBERG, ESQUIRE, 20 Park Plaza, Suite 1000, Suffolk, MA 02116
EFTA01114414
DataSet-10
Unknown
1 pages
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PLAM
BEACH COUNTY, FLORIDA
B.B. Case No: 502009CA037319XXXXMB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
DEPOSITION
PLAINTIFF'S CROSS NOTICE OF TAKING VIDEOTAPED
RNEY WILL TAKE THE DEPOSITION OF:
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTO
DATE AND TIME: LOCATION:
March 24, 2010 Prose Court Reporting
10:00 AM
authorized by law to take depositions in
upon an oral .eiamintition before a Notary Public or officer
day to day until completed. The
the State of New York The oral examination will continue from
trial or are being taken for such
depositions are being taken for-Purposes of discovery, for use at
other purposes as are permitted: Wider the Rules of the Court.
. . • -•
WE HEREBY CERTIFY that a true and
010 to: Jack A. Goldberger
Bruce E. Reinhart, Esq.,
D. Critton, Jr., Michael J. Pike,
LEOPOLD-KU VIN, P.A.
mor
By:
S. veer T. Kuvm , Esq.
No: 089737
Florida Bar
EFTA00723939
DataSet-10
Unknown
1 pages
From: " " alMIE>
To:"
Cc: „
Subject:
Date: Tue, 11 Aug 2020 16:51:05 +0000
Attachments: ranscript_Vol_l_(6-24-16).pdf; ranscript_Vol_2_(6-24-
16).pdf
As we discussed, I'm attaching the deposition transcripts.
Assistant United States Attorney
Southern District of New York
EFTA00087772
DataSet-10
Unknown
180 pages
Original Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
Plaintiff,
vs. CASE No.
502008CA028051XXXXMB AD
JESTRF.Y EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
October, 20, 2009
1010 a.m.
Reported By: Teresa Whalen, RPR, FPR, Notary Public. State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, Ft. 33410
www.eSquiresolutIons.com
3501.172-002
CONFIDENTIAL Page 1 of 180
EFTA_00070845
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•
•
•
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EFTA_00070846
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE No.502008CA028051XXXXMB AB
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
Tuesday, October, 20, 2009
10:10 - 3:30 p.m.
Reported By:
Teresa Whalen, RPR, FPR
Notary Public, State of Florida
West Palm Beach Office Job #118991
Toll Free: 866.709.8777
• 0 Facsimile: 561.394.2621
Suite 600
ESQcTIa . 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
3501.172-002
CONFIDENTIAL Page 3 of 180
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA •
CASE No.08-CV-80119-CIV-MARRA/JOHNSON
4
Plaintiff,
-vs-
7 JEFFREY EPSTEIN,
Defendant.
9 Related cases:
08-80232, 08-80380, 98-80381, 08-80994,
10 08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
11
12
DEPOSITION OF
13 VOLUME II
14
Tuesday, October 20, 2009
15 10:10 - 3:30 p.m.
16
17
18
19
20
21 Reported By:
Teresa Whalen, RPR, FPR
22 Notary Public, State of Florida
West Palm Beach Office Job #118991
23 Phone: 800.330.6952
561.659.4155
24
25
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Bead, Gardens, FL 33410
wvnv.esquiresolullons.com
3501.172-002
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1 APPEARANCES:
2
On behalf of the Defendant:
3
ROBERT D. CRITTON, JR., ESQUIRE
4 BURI4AN CRITTON LUTTLER & COLEMAN, LLP
303 Banyan Boulevard, Suite 400
5 West Palm Beach, Florida 33401
6
7 On behalf of Plaintiff III.:
B
9
10
11
12 On behalf of the Witness:
13
14
15
16
17 On behalf of Defendants/
18
19
20
21 On behalf of Plaintiff in related Case No. 08-80811
22
23
24
25
• 0 Toll Free: 866.709.8777
FaCSIMIle: 561.394.2621
Suitt 000
ESQUIRE 4440 PGA Boulevard
Palm aeach Gardens, FL 33410
www.esqulresolutlons.com
3501.172-002
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2
•
3 INDEX
4
5
6 WITNESS: DIRECT CROSS REDIRECT RECROSS
9 BY MR. 190
10 BY MR. 135 208
11 BY MR. 156
12 BY MR. CRITTON: 173
13
14
15 EXHIBITS
•
16
17
18 NUMBER DESCRIPTION PAGE
19 DEFENDANT'S EX. 1 COPIES, COMPOSITE PHOTOGRAPHS 103
20 DEFENDANT'S EX. 2 COMPOSITE PHONE MESSAGE BOOK 147
21 DEFENDANT'S EX. 3 COPY OF PHOTOGRAPH 162
22
23
24
25
0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
•
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, Fl 33410
www.esquiresolutions.com
3501.172-002
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• 1
2
PROCEEDINGS
3 Deposition taken before Teresa Whalen,
4 Registered Professional Reporter, Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
7
8 (Mr. joined the proceedings in person.)
9 CROSS (
10 BY MR.
11 O Good afternoon. Is it all right if I call you
12 1111111?
13 A Yes.
• 14
15
Q Okay. My name is
represent some plaintiffs in these cases, and it is my
, I also
16 turn to ask you some questions.
17 We were talking about when Mr. Epstein was in
18 jail, which was between June 30th of 2008 and July of
19 2009; correct?
20 A Yes.
21 Q Now, during that time you wont Lu wurk your
22 regular schedule at 358 El Brillo Way; is that correct?
23 A Yes.
24 Q So you were working basically --
25 MR. CRITTON: She's not finished.
Ton Free: 866.709.9777
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Suite 000
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1
2
BY MR.
• I'm sorry. Go ahead.
•
3 : Do you need to expand on your
4 answer?
5 BY MR.
6 O Were you finished?
7 A I worked regular hours, but sometimes there
8 are times that I report eight, sometimes I report
9 nine o'clock.
10 Q And I believe --
11 A It's flexible
12 Q Okay. And it was after he left jail that you
13 started working at 6:00 a.m., correct?
14
15 •
A Yee.
So whether you start work at eight or nine is
•
16 your choice? When you say "it's flexible," it means you
17 can chose whether to come at eight or nine?
18 A Yes. When he was not there.
19 o Okay. it didn't matter whether you there at
20 eight or nine when he was not there, correct?
21 A No.
22 • And what kind of things did you do at the
23 house -- let me ask the question this way.
24 How were your duties different when he was nuL
25 there during the time he was in jail from when he would
Toll Free: 866.709.8777
0
Facsimile: 561.394.2621
Suite 600
•
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• 1
2
come there before he went to jail?
A When he was in jail?
3 • Yes.
4 A I clean the house.
5 • You had less to clean, is that fair to say,
6 because Mr. Epstein, I assume, based on your testimony,
7 there were much fewer people in the house than before,
8 correct?
9 A Yes. I made inventory of the linens.
10 Q I'm sorry?
11 A Of the linens, I made inventory of the liners.
12 Q Oh. Inventory of the linens?
13 A Inventory.
• 14
15
Q Okay. So you did that.
do to fill the time?
And what else did you
16 A Wash the clothes that was in storage, you
17 know.
18 O You washed clothes in storage?
19 A Yes. Because it was right there, so I just
20 wash it and then press if it needs pressing.
21 Q So he has clothes stored outside La the house?
22 A No. In the house.
23 O In the house. Okay. So even if they aadn't
24 been worn, you washed them, correct?
25 A And press them.
Toll Free: 866.709.8777
• 0 Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens. FL 33410
weameseuiresolutions.com
3501.172-002
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1
2
MR. CRITTON:
THE WITNESS:
Form.
Yes.
•
3 BY MR.
4 Q What other type of things did you do while he
5 wasn't there?
6 A If there are plants, I attend to the plants.
7 Q Okay. Is that something you didn't do before
8 he went to jail?
9 A I do that also when before he went to jail.
10 Q Okay.
11 A If there are orchids or plants in the house,
12 then I attend to it.
13 • I guess my question is what kind of projects
14
15
did you work on when he was not there to fill your time
after he went to jail?
•
16 A Cleaning, tidying, just going around the
17 house. If I see something that needs painting, I tell
18 Janusz.
19 Q Now, are you paid on the basis of a yearly
20 salary, or are you paid weekly or monthly; how does that
21 work?
22 A We are paid twice a month.
23 Q Okay. That's when you receive your pay?
24 A Yes.
25 • I guess my question is this: say you have to
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
S
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take a half a day of work off, do you get paid for that?
2 A Yes. In my situation.
3 Q I'm sorry. In your what?
4 A In my situation I was paid.
5 Q Okay. So you're on like a fixed salary, if
6 you miss some time you still get the same amount of
7 money, correct?
8 A Yes.
9 Q And I take it that during the period in which
10 Mr. Epstein was in jail, you continued to receive the
11 same salary, plus a raise, I assume, at the beginning of
12 the year; correct?
13 A Yes.
• 14
15
Q So you continued to receive the same salary
that you did before Mr. Epstein went to jail, correct?
16 A Yes, sir.
17 Q Did Mr. Epstein ever pay bonuses or any extra
18 money to you?
19 A Yes.
20 Q What kind of bonuses did you receive?
21 A Yearly bonus.
22 Q You get a yearly bonus. When is that paid, is
23 that paid at holiday time, Christmas time?
24 A After the year.
25 Q At the end of the year?
Toll Free: 866709.8777
Facsimile: 561.394.2621
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2
1 A
Q
At the end of the year.
At New Years?
•
3 A New Years.
4 • And this past year, when 2008 became 2009, how
5 much of a bonus did you receive?
6 A I did not receive any.
7 Q And what about before that, what kind of bonus
8 did you receive?
9 A The yearly bonus.
10 • Okay. What would be the amount of the yearly
11 bonus?
12 A Oh. For me? The last one I receive was
13 5,000.
14
15
• Okay.
salary of $42,000?
So this would be in addition to your
•
16 A Yes.
17 Q And this $5,000 bonus you would have received
18 in or about January 2008; is that correct?
19 A Not eight.
20 Q Pardon?
21 A Not eight. We did not get any bonus in 2008.
22 Q Okay. So when was the last time you received
23 a $5,000 bonus?
24 A I think 2007.
25 Q So it's been two years since you've gotten a
0 •
Toll Free: 866.709.8777
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1 bonus; is that correct?
2 A Let me see. Yes.
3 Q Okay. Did Mr. Epstein explain to you why he
4 wasn't giving you a bonus in the last two years?
5 A He did not personally told us.
6 • Did someone tell you why you were not getting
7 a bonus?
8 A Janusz was informed, and Janusz informed me.
9 Q Okay. Did Janusz give you a reason why you
10 weren't getting a bonus?
11 A Because of the economy, that's what he said.
12 Q Any other reason that he gave?
13 A No, sir.
14 Q Did you receive a $5,000 bonus for 2006 and
15 2005?
16 A It was different, it gradually increased.
17 Q Okay.
18 A It was not the same amount.
19 • what was the bonus in 2006 and 2005?
20 A 2005 was 2,000.
21 Q Uh-huh.
22 A And then the next is 5,000 and 5,000.
23 • Okay. So correct me if I am wrong, but in
24 January 2005 you received a $2,000 bonus?
25 A Yes.
Toll Free: 866.709.8777
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1
2
Q And at that point in time you had really just
started a month and a half before?
•
3 A No. I want to correct that. I receive a 500
4 after I started there November.
5 Q Yes. November of 2004 you started?
6 A At Christmas I receive, after Christmas I
7 receive $500.
8 Q Okay. So in January of 2005 you receive $500,
9 correct?
10 A Yes.
11 Q Then in January 2006 you received how much?
12 A 2,000.
13 Q And in January 2007 you received 5,000; is
14
15
that correct?
A Yes.
•
16 Q And in January 2008 you received no bonus?
17 A NO.
18 Q Is that correct?
19 A Correct.
20 Q Correct, you received no bonus?
21 A No bonus.
22 Q And the same in January 20U9, correct?
23 A Correct.
24 Q Has Mr. Epstein advised you, discussed with
25 you at all how much of a bonus you're going to receive
•
Toll Free: 866.709.8777
Facsimile: 561.394.2621
0
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• 1
2
after the holidays this year?
A No, sir.
3 Q Has anyone discussed with you what bonus you
4 will receive after the holidays this year?
A No.
6 Q Do you have any expectation as to what kind of
7 bonus you'll receive?
8 A I don't -- I did not expect anything.
O You testified earlier about Lyn, who is the
10 housekeeper in New York, correct?
11 A Yes.
12 Q Now, when was the first time you met Lyn in
13 person?
• 14
15
A
Q
In person? When I went to New York.
And when was the first time you went to
16 Now York?
17 A In 2006.
18 Q 2006. And was the reason you went to New York
19 in 2006 for Ms. Maxwell's party?
20 A No. It was Lyn I think had a surgery.
21 ✓ Okay. And you were there to UUVOL fox her
22 while she had surgery?
23 A Yes.
24 • And how long were you there?
25 A I cannot remember, but after her surgery, then
Toll Free: 866.709.8777
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2
we left to Palm Beach.
Q Okay. You don't remember how long it was?
•
3 A I cannot remember, because I've been there
4 like four times, or more than four times.
5 Q More than four times?
6 A Yes.
7 Q Okay. So this first time when she had her
surgery, you were the housekeeper then in New York while
9 she was out, correct?
10 A Yes, sir.
11 • But did she come into the house in New York
12 and that's how you met her while she was recovering, or
13 how was it that you met her at that time?
14 A We met her before her surgery, I met her
15 before her surgery.
16 Q i see. Then she went and had her surgery.
iv Now, when you traveled to New York, did you go
18 on Mr. Epstein's plane?
19 A No, sir.
20 Q How did you travel to New York?
21 A Commercial.
22 Q So Mr. Epstein purchased you a ticket on an
23 airline to fly to New York?
24 MR. CRITTON: Form.
25 THE WITNESS: Yes, sir.
0 •
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, Fl. 33410
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• 1
2
BY MR.
Q Now, let's talk about the other times that you
3 went, you traveled to New York. When was the next time
4 dfLeL Lyn LeevveLed ftoo het uuLyesy Lhal you weal Lo
5 New York?
6 A I think when she went to the Philippines.
7 Q Okay. She went for like a vacation to go to
visit her family?
9 A No. I'm not really good. There was time
10 went there because I think I sometimes interchange, but
11 I went they, nn, time herauee to rover up for
12 ms. maxwell's housekeeper.
13 Q Okay.
• 14
15
A
Q
And when she was having a party.
Okay. So those are two separate times?
16 A Yea. Two separate times.
17 Q Both relating to Ms. Maxwell?
18 A No. The first one was -- first one to cover
19 up for Lyn.
20 • Right. I understood that. But after that,
21 when you came back --
22 A There was a time -- I don't know the sequence,
23 but you know, there was a time I have to cover up for
24 Ms. Maxwell's housekeeper.
25 • I see. What's her name?
Toll Free: 866.709.8777
Facsimile: 561.394.2621
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2
1
Q
A Florena.
And then there was another time where you went
•
3 to work for this party that she had, correct?
4 A Yes.
Q Okay. And the fourth time?
6 A When Lyn went to the Philippines.
7 Q Okay. About how long were these visits each
8 time?
9 A Sometimes a week, two weeks, then there was a
10 time I stayed there for like a month.
11 Q Which was that, when she had her surgery, Lyn
12 had her surgery, or was this a different time?
13 A Oh, what's this? Let me see. I cannot
14
15
really, what's this?
• Take your time, take your time.
•
16 A Oh. When, what's this, Ms. Maxwell's
17 housekeeper, I was to cover up for her because tor jury
18 duty. And then she was not part of the jury, so my stay
19 there was, like, extended. That's how I was able to
20 help with the party.
21 • She did not get on the jury?
22 A Yes. she was called.
23 Q But you stayed anyway to help with the party?
24 A Yes.
25 Q I think I understand. Now, have you ever,
•
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1 while you've been employed by Mr. Epstein, traveled
•
2 anywhere else for work?
3 A No, sir.
Q Those trips to New York was the only time
a you've traveled?
A Yes, sir.
7 Q You've never gone to New Mexico or to the
8 Virgin Islands for Mr. Epstein?
9 A No.
13 (Plaintiff's Exhibit No. 2 was marked for
II identification.)
12 BY MR.
13 • Let me show you what's been marked Exhibit 2.
• 14
15
Does it look like the paper that you were talking about
earlier where you wrote the names and the time?
16 A Yee, sir.
17 Q Okay. So this is kind of a notebook or a
18 message pad notebook that was I think you said located
19 by the pantry?
20 A Yes, sir.
21 Q can you look through this and cell me if any
22 of these, point out any of those that are in your
23 handwriting?
24 : Take your time, look at each
25 one, and just tell him if you see any that you
Toll Free: 866.709.8777
• 0 Facsirntie: 561.394.2621
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1
2
recognize your handwriting.
MR. CRITTON: You asked her to identify if she
•
3 sees anything in her writing?
4 MR. : Yes.
5 THE WITNESS: (Shaking head.)
6 BY MR.
7 Q Okay. I understand your response is that you
8 reviewed the various message slips included in Exhibit
9 No. 2 and none of them are your writing, correct?
10 A Yes, correct.
11 Q But you do recall writing messages on this
12 type of pad for Mr. Epstein, correct?
13 A Correct.
14
15
MR. CRITTON:
Mr. Rodriguez's deposition?
that was exhibit what at
•
16 MR. : Exhibit 1 at Mr. Rodriguez's
deposition.
18 MR. CRITTON: Okay.
19 BY MR.
20 O In the period 2004 to 2008 before Mr. Epstein
21 went to jail, do you recall whether there were females
22 who were sitting at the pool in the home at 358
23 El Brillo Way who were topless?
24 A There was one time.
25 One time you remember. Tell me what happened
0 •
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that time.
2 A I was tidying the living room, then not
3 really -- there was like part of the wall, so I saw one
4 female there but not really, I saw it like this side
5 (indicating), so...
6 Q She was at the pool, or inside the house?
7 A This side, not really frontal, but on the side
8 I saw only -- I saw her side, not really like...
9 : His question was, was she
10 inside the house or out by the pool when you saw
11 her from the side.
12 THE WITNESS: The question -- they were in the
13 pool.
• 14
15
BY MR.
• okay. So she was not wearing a bathing suit
16 top, correct?
17 A Yes.
18 Q Was she wearing a bathing suit bottom?
19 A I did not know.
20 Q And how did you -- did you do anything in
21 response to this?
22 A No. I went to, what's this, to kitchen and I
23 told Alfredo not to go to the pool.
24 Q And this was the only time you ever remember
25 seeing a girl who wasn't wearing a top at the pool?
Toll Free: 866.709.8777
• 0 Facsimile: 561.394.2621
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3501.172-002
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1
2
A
Q
Yes.
Were there frequently females at the pool to
•
3 the house?
4 A No. Not frequently.
5 Q Not frequently. Sometimes?
6 A Sometimes.
7 Q Mr. Epstein would travel with some females, I
8 think they would come on the plane with him to the
9 house; is that correct?
10 MR. CRITTON: Form.
11 BY MR.
12 Q You can answer.
13 A I cannot remember if they -- let me see. I
14
15
remember Because when Mr. Epstein arrives, most
of the time I'm already off.
•
16 Q Let me ask the question this way: Were there
17 Females other than who would come with Mr. Epstein
18 on the plane and stay at the house?
19 MR. CRITTON: Form, predicate.
20 BY MR.
21 Q Stay overnight at the house?
22 MR. CRITTON: Same.
23 THE WITNESS: I did not know if they came with
24 Mr. Epstein, I did not see.
25
9 Toil Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
•
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BY MR.
2 O Okay. There were females who would stay
3 overnight at the house, but you're not sure how they got
4 to the house; is Lhilt. Lai: W say?
5 A Yes.
6 Q Did any of the females who came to the kitchen
7 entrance to give a massage, did any of them stay
8 overnight?
9 A No, sir.
10 Q Never, correct?
11 A Yes, sir.
12 MR. CRITTON: Did you say correct and she said
13 yes?
• 14
15
MR.
MR. CRITTON:
:
Okay.
Yes.
Thank you.
16 BY MR.
17 • The girl at the pool who was topless, do you
18 recall what her name was?
19 A No.
20 • Do you recall how she got to the house or, you
21 know, what her purpose was in being there?
22 A I cannot remember.
23 O Was she a girl who had come to give
24 Mr. Epstein a massage?
25 MR. CRITTON: Form.
Toll Free: 866.709.8777
Facsimile: 561.394.2621
• Suite 600
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3501.172-002
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1
2 BY MR.
THE WITNESS: No.
•
3 0 The females who came to give Mr. Epstein a
4 massage, did they ever use the pool?
5 MR. CRITTON: Form, predicate.
6 THE WITNESS: I did not see.
7 BY
DataSet-10
Unknown
1 pages
To: Jeffrey Epsteinfleevacationagmail.comj
From: story cowles
Sent Mon 3/22/2010 5:23:27 PM
Subject: Probation tomorrow
What time would you like to go to probation tomorrow?
Edwards deposition is at I Own. Located at
Searcy Denney Scarola Barnhart
2139 Palm Beach Lakes Boulevard
FL 33409-6696
EFTA_R1_01495474
EFTA02426558
DataSet-10
Unknown
1 pages
From:
Sent: Thursday, October 18, 2018 10:56 AM
To: J
Subject: Re: I was asked 10 years ago many times to write deposition against me
Kira showed me this last night but I wasn't =ure why she wanted for me to see it because I've never asked her a=out any
of her medication use etc.
She =aid the other night she wasn't feeling well and was seeking help f=om me and I told her to go to Bellevue, why is
she showing this to us?
MT, 1840=BEKr. 2018 r. a 6:29,1 communication in error, please notify us immediately by
return e-mail=or by e-mail to , and
destroy this communication and all copie= thereof,
including all attachments. copyright -all rights reserved
=/div>
1
EFTA_R1_01825086
EFTA02619801
DataSet-10
Unknown
2 pages
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT 1N AND FOR PALM
BEACH COUNTY, FLORIDA
Case No: 502008CA37319XXXX MB AB
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
ti
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
PATE AND TIME: LOCATION:
October 20, 2009 Esquire Court Reporters
10:00 AM One Penn Plaza
Suite 4715
New York, NY 10119
upon an oral examination before a 14Mir7 Public or officer authorized by law to take depositions in
the State of New York. The oral examihatiowwill continue from day to day until completed. The
depositions are being taken for purposes of 'clisCov
- ery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed this
day of September, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West
e
Palm Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West
Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400,
West Palm Beach, FL 33401.
LEOPOLD-KUV1N, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
BY:
vin,
Bar No: 089737
EFTA00728502
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PLAM
BEACH COUNTY, FLORIDA
N Plaintiff,
Case No: 502009CA037319XXXXMB AB
vs.
JEFFREY EPSTEIN,
Defendant.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITIOAt
PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
DATE AND TIME: LOCATION:
October 19, 2009 Esquire Court Reporters, One
10:00 AM Penn Plaza, Suite 4715, New
York, NY 10119
upon an oral examination before a Notary Public or officer authorized by law to take depositions in
the State of New York. The oral examination will continue from day to day until completed. The
depositions are being taken for purposes of discovery, for use at trial or are being taken for such
other purposes as are permitted under the Rules of the Court.
4 i t REBY CERTIFY that a true and correct copy of this Notice was mailed this E_
day of -- fe 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
Beach, FL 334101; Bruce E. Reinhart Esq., 250 Australian Avenue South, Suite 1400, West Palm
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
S yam" uvin, Esq.
Florida Bar No: 089737
EFTA00728503
DataSet-10
Unknown
2 pages
IN THE CIRCUIT COURT FOR THE
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
FILE NO. 502008CP003626XXXXMB
E.W.,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
CROSS NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that plaintiff, E.W., will take the video deposition of:
NAME DATE AND PLACE OF TAKING DEPOSITON
TIME
Sto Cowles May 12, 2010 US Le al Su ort
@ 10:00 AM
West Palm Beach, FL West Palm Beach FL 33401
upon oral examination before US Legal Support, Notary Public, or any other notary public
or officer authorized by law to take depositions in the State of Florida. The oral
examination will continue from day to day until completed. The depositions are being taken
for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the Rules of Court.
1
EFTA00725916
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
U.S. Mail and email on May , 2009 to: Robert D. Critton, Jr., Esq., Burman, Critton, et
al., 515 North Flagler Drive, Suite 400, West Palm Beach, FL 33401; Jay Howell, Esq., Jay
Howell & Assoc., 644 Cesery Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan
Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West
Palm Beach, FL 33401.
Farmer, Jaffe, Weissing,
Edwards. Fistos & Lehrman, P.L.
Fort Lauderdale, FL 33301
fax
By:
BRADLEY J. EDWARDS
Florida Bar No.:
2
EFTA00725917
DataSet-10
Unknown
1 pages
From: Gmax
Sent: Friday, March 18, 2011 1:10 PM
To: jeevacation@gmail.com
Can I have VR deposition please ASAP
Thx
EFTA_R1_00094349
EFTA01778088
DataSet-10
Unknown
2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Mark Epstein on Monday, September 21, 2009, at 11:00 a.m., at:
Esquire Court Reporters
One Penn Plaza
Suite 4715
New York, NY 10119
The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
and shall continue day to day, weekends and holidays excepted, until completed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
by U.S. Mail and email transmission this //4'day of August, 2009 to all those on the
attached Service List.
EFTA00750921
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauder ale. Florida 33301
By:
BRAD EDWARD
Florida Bar No.:
cc: Esquire Court Reporters
EFTA00750922