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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 at,
Defendant(s).
OMNIBUS ORDER IN REGARD TO UPDATE DEPOSITION OF THE PLAINTIFF
THIS CAUSE came before the Court upon various Motions in regard to the
Defendant, BRADLEY J. EDWARDS' request for update deposition of JEFFREY EPSTEIN,
as well as a Request to Produce served upon EDWARDS and Motions to Impose Sanctions
against JEFFREY EPSTEIN. The Court has heard argument and has reviewed the
pleadings and is otherwise fully advised in the premises. Based upon the foregoing, it is
CONSIDERED, ORDERED AND ADJUDGED as follows:
The Defendant shall be entitled to take an update deposition of the Plaintiff
in regard to the specific issues identified and more specifically relating to public
statements made by the Plaintiff regarding his criminal activity, testimony dealing with
any claim the Plaintiff has waived his Fifth Amendment rights and/or has otherwise lost
his Fifth Amendment rights. The Defendant EDWARDS' Motion to Compel and Impose
Sanctions for Failure to Attend the Deposition is denied. In regard to the Request to
Produce submitted to the Defendant EDWARDS by the Plaintiff under certificate of service
the 7th day of April, 2011, the Court recognizes that there is a difference between "fact
work product", "opinion work product", and "contention discovery". "Opinion work
product" is almost never discoverable, "fact work product" is discoverable under limited
circumstances, and, according to the most recent pronouncements from the Fourth
District, "contention discovery" is allowed. Therefore, the Defendant shall respond to the
EFTA01082063
Request to Produce and assert any privilege in a privilege log, including any work product
privileges. The Defendant may do so in a manner which will not divulge or otherwise
disclose the nature of the documentation itself and if the parties cannot agree, the
documents shall be submitted to the Court for an in camera review to determine whether
the matters constitute "fact work product", "opinion work product" or merely "contention
discovery".
DONE AND ORDERED this j -aayieifJuly, 2011 at West Palm Beach, Palm
Beach County, Florida.
:
,.(woo L./
DAVIT FICROW
CIRCUIT COURT JUDGE
Copy furnished:
JACK SCAROLA, ESQUIRE, FL 33409
JOSEPH L. ACKERMAN, JR., ESQUIRE, , West Palm
Beach, FL 33401
JACK GOLDBERGER, ES , West Palm Beach, FL 33401
MARC NURIK, ESQUIRE, uderdale, FL 33301
GARY M. FARMER, JR., ESQUIR , Ft. Lauderdale, FL 33301
MARTIN WEINBERG, ESQUIRE, , Suffolk, MA 02116
EFTA01082064
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To: Jefffrey E stein[jeevacation©gmailcoml
From:
Sent: Wed 10/10/2018 5:08:34 PM
Subject: David Mitchell
Please call David Mitchell on his cell. He is at a deposition right now but says
he will pick up.
Sent from my iPhone
EFTA_R1_01056438
EFTA02259879
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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 One Clearlake Centre
250 S. Australian Avenue
Suite 1500
West Palm Beach, FL 33401
by law to take depositions in
upon an oral .eitunintition before a Notary Public or officer authorized
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 foi.iurposes of discovery, for use at
other purposes as are permitted:Wider the Rules of the Court,
WE HEREBY CERTIFY that a true and correct copy of this Notic
e was mailed this U.
alian Aven ue, Suite 1400, West Palm
day of February, 2010 to: Jack A. Goldberger, Esq., 250 Austr
ue South, Suite 1400, West Palm
BtaCh, FL 33401; Bruce E. Reinhart, Esq., 250 Australian Aven
North Flagler Drive, Suite 400, West
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515
Palm Beach, FL 33401.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Pgjm Beach Gardens, FL 33410
By:
SpeKcer T. Kuvm, Esq.
Florida Bar No: 089737
EFTA00764058
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7 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 10.80309
JANE DOE NO. 103
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
CROSS-NOTICE OF TAKING DEPOSITION DUCES TECUM
(Undersigned Counsel Will be Appearing by Phone)
PLEASE TAKE NOTICE that at the below listed time and place the Plaintiff, JANE DOE
NO. 103, by and through undersigned counsel, will take the deposition duces tecum (See attached
Exhibit "A") of:
NAME OF DEPONENT DATE AND TIME PLACE OF DEPOSITION
Records Custodian Wednesday US Legal Support
New York Daily News March 31, 2010 1 Penn Plz, #1410
c/o Legal Department 2:30 p.m. New York, NY 10119-1410
Attn: Anne Carrot Phone: (212) 759-6014
450, West 33id Street
New York, NY 10001
upon oral examination before US Legal Support, a 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. This deposition is being taken for the purpose of
Podhurst Orseck, P.A.
25 West Waster Street, Suite 800. Miami, FL 33130, Miami 305.3582900 Fax 305.35&2382 • Pat Lauderdale 954.4634346 I www.podhurst.com
EFTA00726154
CASE NO.: 10-80309
discovery, for use at trial, or for such other purposes as are permitted under the rules of Court.
DATED thisacas-day of March, 2010.
Respectfully submitted,
PODHURST ORSECK, P.A.
Attorneysfor PlaintiffJane Doe No. 103
By:
Robert C. Josefsberg
Fla. Bar No. 040856
Fla. Bar No. 114771
try adorn at c to ding
25 W. Flagler Street, Suite 800
Miami, FL 33130
Telephone
Facsimile:
-2-
Podhurst Orsecic P.A.
25 Wet Meer Street, Suite 800, Miami, FL 33130, Mete vele* 2800 Fax 3053582382 • Fort Lauderdale 9564634346 I www.podhurstcom
EFTA00726155
CASE NO.: 10-80309
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on diisol‘tay of March, 2010, a copy of the foregoing was
served this day on all counsel of record on the attached Service List via e-mail transmission.
Respectfully submitted,
PODHURST ORSECK, P.A.
Attorneysfor Plaintiffs Jane Doe No. 103
By: W. t
C. JosefsberW
Fla. Bar No. 040856
riosefsber4podhurst.com
Katherine W. Ezell
Fla. Bar No. 114771
kezdell(Woodhurst.com
City National Bank Building
25 W. Flagler Street, Suite 800
Miami, FL 33130
Telephone: (305) 358-2800
Facsimile: (305) 358-2382
-3-
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, 11.. 33130, Miami 305358.1930 Fax 305 gra 74131 • Ret Lauderdale 954.463.4346 www.podlarstrem
EFTA00726156
CASE NO.: 10-80309
SERVICE LIST
JANE DOE NO. 103 v. JEFFREY EPSTEIN
Case No.: 10-80309
United States District Court, Southern District of Florida
Critton, Esq.
Michael J. Pike, Esq.
Burman, Critton, Luther & Coleman LLP
303 Banyan Boulevard, Suite 400
West Palm Beach, FL 33401
Phone: (561) 842-2820/Fax: (561) 515-3148
red viaciciaw.com
mpike@bc1claw.corn
Counselfor Defendant, Jeffrey Epstein
Jack Goldberger, Esq.
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 659-8300/Fax: (561) 835-8691
jaeesoebellsouthmet
Co-Counselfor Defendant, Jeffrey Epstein
Bruce E. Reinhart, Esq.
Bruce E. Reinhart, P.A.
250 South Australian Avenue, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 202-6360/Fax: (561) 828-0983
ecf@brucereinhartlaw.com
Counselfor Co-Defendant,
Jack Scarola, Esq.
Jack P. U, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300/Fax: (561) 383-9456
jsx@scarcvlaw.com
-4-
Podhurst Orseck, P.A.
25 West Hagler Street, Suite goo, Miami. FL 33130, Miami 3126.3582800 Fax 305 Vara , • Fon Laudemlale 954.463.4346 vnvw.podhorstcom
EFTA00726157
CASE NO.: 10-80309
iph@searcvlaw.com
Counselfor Plaintiff in related Case No. 0840811
Adam Horowitz, Esq.
Stuart Mermelstein, Esq.
Mermelstein & Horowitz, P.A.
18205 Biscayne Blvd., Suite 2218
Miami, FL 33160
Phone: (305) 931-2200/Fax: (305) 931-0877
aborowitz@sexabuseattomev.com
§mermelsteinOsexabuseattorney.com
Counselfor Plaintiffs in Related Cases Nos. 0840069, 08-80119,08-80232, 08-80380, 08-80381,
08-80993, 0840994
Spencer Todd Kuvin, Esq.
Theodore Jon Leopold, Esq.
Leopold Kuvin, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
Phone: (561) 515-1400/Fax: (561) 515-1401
slcuvin@Jeopoldkuvin.com
tleopoldlaileopoldkuvin.com
Counselfor Plaintiff in Related Case No. 08-08804
Richard Willits, Esq.
Richard H. Willits, P.A.
2290 10th Ave North, Suite 404
Lake Worth, FL 33461
Phone: (561) 582-7600/Fax: (561) 588-8819
Iawverwillits@aol.com
reelrhwti,thotmail.com
Counselfor Plaintiff-in Related Case No. 0840811
Edwards, Esq.
Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: 954 524-2820/Fax: (954) 524-2822
Counselfor Plaint/firin Related Case No. 08-80893
-5-
Podhurst Orseck, P.A.
25 West Waster Street Suite SOD, Miami, FL 33130, Mani 303358.2300 Fax 305.356_2332 • Fat Lauderdale 954.463.4346 I www.podhuistecat
EFTA00726158
CASE NO.: 1040309
Isidro Manuel M, Esq.
Elkins & Bothringer
224 Datum Avenue, Suite 900
West Palm Beach, FL 33401
Phone: (561) 832-8033/Fax: (561) 832-7137
isidrogarcia@bellsouth.net
Counselfor Plaintiffin Related Case No. 0840469
-6-
Podhurst Orsecic, P.A.
25 West Hagler Street, Suite 800, Miami, EL 33130, Miami 305.3582800 Pax 305.3582382 • Fort Lauderdale 951.463.4346 www.podhurstcom
EFTA00726159
Exhibit "A" — DUCES TECUM
All taped conversations between George Rush and Jeffrey Edward Epstein,
including telephone recordings, all emails to and from Jeffrey Edward Epstein or
someone representing themselves to be Jeffrey Epstein.
EFTA00726160
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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
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
EFTA00750925
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale. Florida 33301
B
BRAD EDWARD
Florida Bar No.:
cc: Esquire Court Reporters
EFTA00750926
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2 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80893CIV -MARRA/JOHNSON
JANE DOE,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
/
Re-NOTICE OF TAKING VIDEOTAPED DEPOSITION
PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
Donald Trump on, September 24, 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 2 51- day of August, 2009 to all those on the
attached Service List.
EFTA00729004
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel: (954) 522-3456
Fax: (9
Email:
By:
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reports
EFTA00729005
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2 pages
From: "Lisa B. Toney" <
To:' 'C
Cc: "CHRISTOPHER E. KNIGHT" I
Subject: Tomorrow's deposition
Date: Tue, 24 May 2011 14:19:10 +0000
Inline-Images: image00 1 jpg; image002.png
Lesley,
The main reception lobby for Dewey & LeBoeuf is located on the 23rd floor. This will confirm that they will
meet at 10:00 am in the lobby of Dewey & LeBoeuf.
Please let me know if you need anything further.
Best regards,
Lisa
2,Description: Description: http://www.fowler-
white.cornisig/FWB_Iogo_240pixels.png
D Lisa B. Toney
LEGAL ASSISTANT TO
CHRISTOPHER E. KNIGHT
Espirito Santo Plaza
1395 Bridtell Avenue
14th Floor
Miami, Florida 33131
**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
EFTA00433434
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.
EFTA00433435
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69 pages
5/19/22,4:19 PM titESTROC(O A e.c--76F, Ghiabine Maxwell - VVIlcipedla CF X
- 0A4- be -01 \.tb
A.?4 tiv
Details of a civil lawsuit, made public in January 2015, contained a deposition from "Jane Doe 3"
that accused Maxwell of recruiting her in 1999, when she was a minor, and grooming her to
provide sexual services for Epstein. Zs A 2018 exposé by Julie K. Brown in the Miami Herald
revealed Jane Doe 3 to be yi_Tinia Giuffre, who was previously known as Virginia Roberts. Giuffre
met Maxwell at Donald Trump's Mar-a-Lago Club in Palm Beach, Florida, when Giuffre was a 16-
year-old spa attendant.(2-A She asserted that Maxwell had introduced her to Epstein, after which
she was "groomed by the two [of them] for his pleasure, including lessons in Epstein's preferences
during oral sex".r?-2103,1
Maxwell has repeatedly denied any involvement in Epstein's crimes.1 In a 2015 statement,
Maxwell rejected allegations that she has acted as a procurer for Epstein and denied that she had
"facilitated Prince Andrew's [alleged] acts of sexual abuse". Her spokesperson said "the allegations
made against Ghislaine Maxwell are untrue" and she "strongly denies allegations of an unsavoury
nature, which have appeared in the British press and elsewhere, and reserves her right to seek
redress at the repetition of such old defamatory claims".(581[641
Giuffre asserted that Maxwell and Epstein had trafficked her and other underage girls, often at sex
parties hosted by Epstein at his homes in New York, New Mexico, Palm Beach, and the United
States Virgin Islands. Maxwell called her a liar. Giuffre sued kaxwell for aefimation in federal
court in the Southern District of New York in 2015. While details of the settlement have not been
made public, in May 2017 the case was settled in Giuffre's favour,16s1 with Maxwell paying Giuffre
"millions". Lt.6-1
Sarah Ransome v Epstein and Maxwell (2017)
In 2017, Sarah Ransome filed a suit, in the United States District Court for the Southern District of
New York, against Epstein and Maxwell, alleging that Maxwell hired her to give massages to
Epstein and later threatened to physically harm her or destroy her career prospects if she did not
comply with their sexual demands at his mansion in New York and on his private Caribbean
island, Little Saint James. The suit was settled in 2018 under undisclosed terms.01[48](671[68]
Affidavit filed by Maria Farmer (2019)
On 16 April 2019, Maria Farmer went public and filed a sworn affidavit in federal court in New
York, alleging that she and her 15-year-old sister, Annie, had been sexually assaulted by Epstein
and Maxwell in separate locations in 1996. Farmer's affidavit was filed in support of a defamation
suit by Virginia Giuffre against Alan Dershowitz.i641 According to the affidavit, Farmer had met
Maxwell and Epstein at a New York art gallery reception in 1995. The affidavit says that in the
summer of the following year, they hired her to work on an art project in billionaire businessman
Leslie Wexner's Ohio mansion, where she was then sexually assaulted by both Maxwell and
Epstein.[7 l Farmer reported the incident to the New York Police Department and the
FBI 152][72] Her affidavit also stated that during the same summer, Epstein flew her then 15-year-
old sister, Annie, to his New Mexico property where he and Maxwell molested her on a massage
table.r7O743
Farmer was interviewed for CBS This Morning in November 2019 where she detailed the 1996
assault and alleged that Maxwell had threatened both her career and her life after the assault:MI
Jennifer Araoz v Epstein's estate, Maxwell, and Jane Does 1-3 (2019)
hltrfien.wikieedla.oreAvikl/Ghlslarne Maxwell 5/28
EFTA00264371
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EFTA00264372
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Epstein attended local public schools, first attending Public School 188, and then Mark Twain
Junior High School nearby.L- 261 In 1967, Epstein attended the National Music Camp at the
Interlochen Center for the Artsc[al He began playing the piano when he was five.E321 He graduated
in 1969 from Lafayette High School at age 16, having skipped two grades./. 1 Later that year, he
attended classes at Cooper Union until he changed colleges in 1971.12a2 From September 1971, he
attended the Courant Institute of Mathematical Sciences at New York University, but left without
receiving a degree in June 1.97.4.1
Career
Teaching
Epstein started working in September 1974 as a physics and mathematics teacher for teens at the
Dalton Schookon the Upper East Side of Manhattan.DILV1 Donald Barr, who served as the
headmaster until June 1974,134A35O6-1 was known to have made several unconventional
recruitments at the time, although it is unclear whether he had a direct role in hiring
Epstein.f.33X37KA Three months after Barr's departure, Epstein began to teach at the school,
despite his lack of credentials.W1 Epstein allegedly showed inappropriate behavior toward
underage students at the time.13111371 He became acquainted with Alan Greenberg, the chief
executive officer of Bear Stearns, whose son and daughter were attending the school. Greenberg's
daughter, Lynne Koeppel, pointed to a parent-teacher conference where Epstein influenced
another Dalton parent into advocating for him to Greenberg.1351 In June 1976, after Epstein was
dismissed from Dalton for "poor performance",L13-N304°) Greenberg offered him a job at Bear
Stearns Laski]
Banking
Epstein joined Bear Stearns in 1976 as a low-level junior assistant to a floor trader.f€l He swiftly
moved up to become an options trader, working in the special products division, and then advised
the' bank's wealthiest clients, such as Seagram president Edgar Bronfman, on tax mitigation
strategies.132)(43]144) Jimmy Cayne, the bank's later chief executive officer, praised Epstein's skill
with wealthy clients and complex products. In 198o, four years after joining Bear Stearns, Epstein
became a limited partner.
In 1981, he was asked to leave Bear Stearns for, according to his sworn testimony, being guilty of a
"Re% D violation".14aVIA Even though Epstein departed abruptly, he remained close to Cayne
and Greenberg and was a client of Bear Stearns until its collapse in 2oo8.10-1
Financial consulting
In A t 1981, Epstein founded his own consulting firm, Intercontinental Assets Group Inc.
(IAG)), i which assisted clients in recovering stolen money from fraudulent brokers and
lawyers. Epstein delis-Med his work at this time as being a evel bounty hunter. He told
friends e worked sometimes as a consultant for overnments and the very wealthy over
embezzled funds, while at other tim a worked for clients who had embezzled funra °1[47i
Spanish actress and heiress Ana Obreg6n was one such wealthy client, whom Epstein helped in
1982 to recover her father's millions in lost investments, which had disappeared when Drysdale
Government Securities collapsed because of fraud.al
https://en.wikipedia.orgAviki/Jeffrey_Epstein
3/80
EFTA00264373
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EFTA00264374
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Non-prosecution agreement (NPA) (2006-2008) DES-Mt.:CC-10N Ces RJR
-t-TTR_ct ATE \i‘..cTtri I aca 1
In July 2006, the FBI began its own investigation of Epstein,
nicknamed "Operation Leap Vear".111-91 It resulted in a 53-page
indictment in June 2oo7.1-713 Alexaiider Acosta, then the U S. Attorney
for the Southern District of Florida, agreed to a plea deal, which Alan
DershoWiiiiielped to negotiate:IAO to grant immunity from all federal
••••••••••ast ..••..ono •
• •,••••
criminal charges to Epstein, along with four named co-conspirators
and any unnamed "potential co-conspirators". According to the
Miami Herald, the non-prosecution agreement "essentially shut down
an ongoing FBI probe into whether there were more victims and other
powerful people whit took part in Epstein's sex crimes". At the time,
this halted the investigation and sealed the indictment The Miami
Herald said: "Acosta agreed, despite a federal law to the contrary, that The controversial non-
prosecution agreement
the deal would be kept from the victims."-VI
Acosta later said he offered a lenient plea deal because he was told
grade" and to "leave it
that Epstein "belonged to intelligence", was "above his pay
to two felony prostitution
alone"..151-Rill412-1 Epstein agreed to plead guilty in Florida state court
restitution to three dozen
charges, serve 18 months in prison, register as a sex offender, and pay
as a "sweetheart
victims identified by the FBI.alfftl The plea deal was later described
A federal judge later found that the prosecutors had violated External video
the victims' rights in that they had concealed the agreement pocumentary: Who is Jeffrey.
from the victims and instead urged them to have
Epstein, accused of semelly
"patience". 1141[451 abusing teen gins? (https:ilwww.you.
tube,com/yuatcp?y=1.WPzW9g9sy)
According to an internal review conducted by the Department
e of Profe ssion allles pons ibilit y, whic h was Perversion of Justice, lyliamttferall,
of Justi ce's Offic
mber 29, 2018.
released in govember 2020, Acosta showed "poor judgment" Nove
in granting Epstein a non-prosecution agreement and failing
to notify Epstein's alleged victims about this agreementigg
Conviction and sentencing (2008-2011)
charge (one of two) of procuring for
On June 3o, 2008, after Epstein pleaded guilty to a state
a girl below age 18,1-P -71 he was sente nced to 18 months in prison. While most
prostitutio n
Epstein was instead housed in a private
convicted sex offenders in Florida are sent to state prison, ding to the sheriffs office, was after
wing of the Palm Beach County Stockade and, accorup to 12 hours a day, 6 days a week. This
for
31/2 months allowed to leave the jail on "work release"
maximum remaining sentence of io months and
contravened the sheriffs own policies requiring a
He was allowed to come and go outside of
making:sex offenders ineligible for the privilege.
1991
specified release hours.
ision
cell door wasl eft unloc ked, and he had acces s to the attorney mom where a telev He
Epstein's infirmary.
the Stockade's previously unstaffed
was installed for him, before he was moved to ly befor e reporting to jail; he dissolved it
foun datio n he had creat ed short
worked at the office of a recei ved $128,000 from Epstein's non-profit to
d his time . The Sher iffs Offic e
after he had serve during his work release. His office was monitored
pay for the costs of extra servi ces being prov ided suits, and
it depu ties" whos e overt ime was paid by Epstein. They were required to wear
by "perm
omed guest s" at the "fron t desk" . Later the Sheriffs Office said these guest logs
checked in "welc
per the depa rtme nt's "reco rds reten tion" rules (although inexplicably the Stockade
were destroyed own driver to drive him between jail and his
not).L u@i He was allow ed to use his
visitor logs were [ioo][u8]
EFTA00264375
!WEIN it‘'JC Fog ruNc ri\IC
tVt•JCJQPirtC.AVS ► C.-•\1et-OP tvle\TT
REFER TO FOLoCA 3 eLeci toRistA NEXT messocAc..5
VIC,vk 0NNAtlaC OF t3 C & C .(i INOOLOEMSCT IN a 0( 9 4"
Ki R.E. PL-`i
25th June 2019
Dear Mr Gates,
I would like to introduce myself, my name is and i am a resident of
South Australia. I have resided in numerous small communities of South Australia and
various city locations within Australia. While residing within these numerous locations i
have been involved in submitting various suggestions of infrastructure changes and new
ideas to make improvements to the districts communities facilities and established
Infrastructures which has been recognised and implemented within the districts councils
and development boards.
My qualifications include Small Business Management, Business Administration and i
have developed numerous written business plans and proceeded to develop the
concepts to the completed stages of establishment.
Registered businesses include :
McDiarmid Woodcraft - 2003
J Monequic - 2011
JC INNOVATIONS - Current - 2019
I have also developed my skills into that of writing novels and currently have a
publishing contract with Austin Macauley Publishing, London, U.K and the release of my
first book will be this year, with two subsequent books to be submitted and published
over the next couple of years.
I have been made aware of your remarkable interest and contributions to community
projects, worldwide issues and scientific research through my partner who is currently a
Professor and Director of Research at the University of Adelaide, South Australia.
I have contacted you to submit numerous business concepts / ideas and a scientific
concept / development that I have developed and designed that addresses issues within
various geographical locations within Australia and across the world, and of which may
be of interest to you, and, or to be considered for development.
The Youth Housing Project, Port Pine was submitted to the Port Pine Council who
proceeded to'submit the project to the South Australian Housing Commission who then
proceeded to submit it to the South Australian Government. It was then reviewed and
considered but was rejected for funding and development by the South Australian
Government, but i was not made aware of the reasons behind the project being rejected.
EFTA00264376
Although this development was designed for the region of Port Pirie to facilitate the
and
resources available i do feel that there is insufficient resources available Australia
be
worldwide within this area of development for the public and feel that the concept can
used as a model to develop and construct this concept to facilitate the shortage of
affordable housing for the youth who wish to relocate to different locations for
employment or move out of home for various reasons and should be considered.
The Housing Project, Glenside was developed and designed in consideration to the
vacant and abandoned buildings that surrounded the grounds of the hospital and was
submitted to the manager of the hospital in February 2017 for consideration but was
rejected as I was informed that the vacant buildings were allocated to another
development. I am unaware whether the development was submitted for consideration
with any other department, including the South Australian Government, although I have
been made aware that the concept was developed into the form of student housing /
apartments that were developed in other locations after the dated submission of the
project, of which I received no acknowledgment.
I would also like to raise the concern and awareness of which I feel is a worldwide issue
and refers to the viewing material on Porn sites that is projected and marketed to society
in the form of suggestions of committing illegal actions and immoral behavior, for
example, to name a few :
Teachers with students
Family members conducting actions of incest
Animal sex
Older men engaging sexually with young girls and or taking their virginity
Rough / Violent / Abusive sex
Labelling women as sluts
I believe this raises the question of what impact this material may have Psychologically
on the viewer, the public, which could manifest into that viewer conducting themselves in
such behavior and illegal actions.
I also feel that in regards to the legal age of 18 of people who can enter into the sex trade
should be scrutinized and reviewed as being too young. As a teenager, an under
developed mind that does not yet have the experience or knowledge of life experience to
make mature decisions or to be responsible within their actions and are denied the right
to drink or acquire a licence in some countries based upon this evaluation until the age of
21, therefore how can they make or be capable of making this decision as a mature adult.
I do feel that this is an issue within our society and is damaging to the youth, to society
and is placing society in real danger, manifesting in sexual crimes and abuse being
committed and the inexperienced youth being taken advantage of and being introduced
to criminality in the form of alcohol abuse, drug use, violent, intimidating behaviour and
crime figures which lead to Prostitution.
I feel that this issue needs to be urgently raised with governing figures and addressed
seriously to be reformed, restructured which leads to the bill of decriminalizing
Prostitution that opens the door to criminality and criminal figures to operate legally within
this industry,to be denied and rejected to discourage this kind of practice within society
and to protect society and the youth from criminal activity.
I am raising this concern, your awareness and offering my perspective as a concerned
member of the public in the instance that you may have the same perspective and may
be in a position or have influence to bring this issue into awareness within the public or
the correct people and or governing figures which may result in action being taken.
EFTA00264377
Personal details and the business concepts / developments that have been provided are
of a confidential nature and i would appreciate your confidentiality concerning this
information.
I would appreciate your consideration concerning the developments / concepts and the
information of which i have provided. Thank you.
Kind Regards
Email :
Kcce‘vEc)
EFTA00264378
2/10t22. 1:08 PM Microsoft Editor, spellng and grammar checker
IA:55154/ . E„SS oN Cr ,BILL-- CAP -ES --O,MGR‘c_fr)
Et9W1 l.E acR 2c I c2c90 I hope they become orgenteedIfor the next show
L'• Inbc/ 17
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- aoi6 EP/SY EDITOR - NOT IIJ3370"--E0 ON Pr COMPcrrE ,
Pft1°P)C-Y otAw I-cl& Microsoft Editor - BILL GATES
Write with style and confidence
riMERicf),
Write more clearly and concisely, anywhere you write, with help from Microsoft Editor.
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that help strengthen your spelling, grammar, and style, let Microsoft Editor be
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punctuation errors.
Learn more about grammar > Learn more about spelling >
EFTA00264379
PStJGVA-T t Gi•15 1,0Jeudetilek.)75
Page 1 of 2
IThgt ( Fe IJOtt\)C.
Re: Confidential - Enquiry - Business Concepts - South Australia
Nicole Ross <
Wed 11/09/2019 10:28 AM
To:
Hi
Unfortunately this doesn't fit within the scope of my program. Best of luck!
Best,
Nicole
On Tue, 10 Sep 2019 at 04:27,
wrote:
Dear Nicole Ross,
I am writing to attract your attention on a number of business concepts that i have
prepared during the past years, for which i am seeking support, either financially or
logistically, or both. All of these aim to address issues of our modern society and
support disadvantaged communities as well as advancing other areas, including medical
science and research.
Over the past decades, i have resided in numerous small communities of South
Australia and various city locations within Australia. During that time, i have submitted
various suggestions of infrastructure changes and new ideas to make improvements to
the districts community facilities and established infrastructures.
In several instances, these suggestions have received positive feedback and, where
possible, were implemented within the relevant district councils and development
boards. However, several have not been submitted or received the attention they
deserve and therefore remain open to development and implementation.
I am well aware of your remarkable interest and contributions to community projects,
worldwide issues and scientific research and therefore upon your interest i am able to
submit four concepts for your consideration, which have been constructed into
executive summaries, taking advantage of my qualifications and expertise in the field of
Small Business Management and Business Administration, hoping that they will be of
interest to you and your foundation to the extent that you would consider them for
development in Australia and/or other countries.
The projects include: a Youth Housing Project ; a Food Waste Management Project ; a
Decontamination Project to prevent microbial infections ; and a Targeted Human Cell
Administration Project with the objective of directly targeting cancer cell masses within
the body, with the potential of advancement to address other medical issues.
As the proposed projects are of a Confidential nature, i will request your confidentiality
on the concepts and information provided if considered for your review and upon
submitting.
EFTA00264380
2(12122. 9:35 Mkt \) f 1 7 rg ta/I 1- 1 t- 1\ I 14
/ _14
/ ._ Jay Weatherill- Wildperlea
Four hours after the close of polls, at approximately iopm ACDST, incumbent Premier Jay
Weatherill telephoned Steven Marshall and conceded defeat. Weatherill subsequently publicly
announced that he had conceded, saying, "I'm sorry I couldn't bring home another victory, but I do
feel like one of those horses that has won four Melbourne Cups and I think the handicap has
caught up with us on this occasion.4771E7811120°3
Peter Malinauskas became Leader of the Opposition and succeeded Weatherill who had resigned
as Labor leader, with Susan Close as deputy, following a Labor caucus meeting on 9 April 2018.(81]
C_CKI-sPreCt-7 ,C,C>cLuk, Itic)R.CETMI C
Post-politics - ft ces--Eptce ugt pt`1 - Vi Ncenr 6OWNE 1:5-titti, C iti—ORD
41n June 2019, he was appointed as an industry professor at the University of South Austral!—16
ia.[82-]
In July 2019, he was appointed to conduct a review of Federal Labor's loss at the 2019 Australian
federal election.E831 In 2021, he was reported to have moved to Perth, Western Australia and be
------
working for -Andrew Forrest's Minderoo Foundation, promoting an early childhood development
campaign nathed Thrive byFive.L8A
"3",47 PICA-Tr' ERkt-t_ - 02019 f\rt.-/ INI r5C t
Honours Q t 1\4 CENT 50C -ONE :
In the 2021 Australia Day Honours, Weatherill was awarded Officer of the Order of Australia for
"distinguished service to the people and Parliament of South Australia, particularly as Premier,
and to early childhood and tertiary education".[851
Personal life
Weatherill is married to Melissa, and they have two young daughters.18±1 He is a supporter of the
Port Adelaide Football Club.(871
&(:)- D6Fr-Crt, Rez_tanu Media > News K. Hon Julia Guard AC University of Adelaidfpublic lecture 2019
CC.) *- Pc:) v lisicENi aOLeNyEit AbELM DE ON k5 (TY
•)-CA • 020t 9 Cc ( RED 1--11•1C4 ,
News Media
* releases
41-he Hontulia Gillard Universitt
oAdelaid tur02-01Vr-
3 September 2019
Media
Friends, I trust you will indulge me if I start by sneaking in a contacts
quick family acknowledgement of my niece Dr Jenna
Malone, who is an academic at this university's Waite
Mental
Research Institute and her great friend Judy Rathjen, who health
is an accomplished woman in her own right and, in a reporting
guidelines
connected Adelaide kind of way, is our Vice Chancellor's
sister.
Statistics
I Elise, acknowledge Judy's brother, Vice Chancellor, Mr
Peter Rathien, Professor Jenny ShavethAlinister for
Health, the Honourable Stephen Wade nd the'kShadow Latest news
Minister for Health, the Honourable Chris Picton.
stories
But most importantly of all, I acknowledge the traditional
owners of the land on which we meet and in the spirit of
reconciliation, pay my respects to Elders past and present.
Yellaka, thank you for your warm Greeting to Country.
Introduction
The is the second time I have had the privilege of being so
welcomed by Yellaka. The first time was at the recent South
Australian State dinner to celebrate 125 years of women's
suffrage in our State — a milestone to be inspired by.
EFTA00264382
.00,10t.16 1:)Firi NG 5iTES- cc:NT( Nit3e-L- cri wspmEn tseko rat
:71+RCti_71 NC; QOP-1 - ac I roe-co4 KIc DEN ED REPCRTED
L-/ P-CtAL-- peri wry, pon piRic - -4 \hAce-m- ie,
oLotE-Ak
2018 CONTINUAL SEXUAL TARGETING FOLLOWING DETENTION AND
RELOCATION - ADELAIDE UNIVERSITY INVOLVEMENT - DATING SITES -
PERSONAL CONTACT - INTELLECTUAL PROPERTY THEFT - GOVERNMENT
CONNECTIONS - INVOLVEMENT WITH PROSTTTUTIONS - GOVERNMENT
TARGETING - SECOND ATTEMPT ON ATTEMPTED MURDER TO APPEAR AS
SUICIDE - FAMILY INVOLVEMENT IN CRIMINAL ACTIVITY
2013 - 2018 BOOK DEVELOPMENT IN PROGRESS - 2018 OBTAINED PUBLISHING
CONTRACT
2014 - 2016 HAND WRITTEN BUSINESS CONCEPTS UNDER DEVELOPMENT - 2016
BUSINESS PROPOSAL PHARMACEUTICAL COMPANY
2017 - 2018 JC DESIGNS, KADINA - REGISTERED BUSINESS - BUSINESS CONCEPTS
UNDER DEVELOPMENT / HAND WRITTEN CONCEPTS 2014 - 2016 INSTALLED ON
COMPUTER - SIGHTED BY PETER HARDER, KADINA COPPER COAST COUNCIL
VINCENT BULONE CE ,SWEDEN ADELAID
),„ ESA - KTH SWEDEN
UNIVERSITY / ADELAIDE UNIVERSITY SA - DIRECTOR OF RESEARCH /
PR
PH delaide
, PH
r5rAdelai
Email :
Viber / phone app elaide
Viber / phone app Sweden
Whatapp / phone Adelaide
* ONLINE DATING SITE / AMM (Adult Match Maker ) - PERSONAL CONTACT *
elocated following detention Glenside Mental Health Facility from Port Pink to parents g
r home 65 Stirling Terrace, Kadina SA. Still on medication prescribed by SACAT for falsified
diagnosis of Schizophrenia, side effects of medication - Suicidal Tendencies
I was under the impression that the illegal targeting and activity was confined to Port Pirie
and revolved around the contesting of the Intellectual property Theft of the Medical
Business Plan and M.S.LC, communication tool developed between the years of 2006 - 2012.
I believed that the targeting involved Roger Kirchner, Michael Fetherstonhaugh and Dr
Kajani all residing in Port Pirie. I received a denial of investigation and the activity from
the
• LC.A.0 2016 - 2017 and believed that I could not take the matter any further and that
Kadina.
activity that had ceased following relocation had ceased due to the relocation to
and
I packed away the evidence and stopped contesting and reporting the illegal activity
the book
Intellectual Property Theft and continued to rebuild my life and my work on
development. I gained employment in the local area of Kadina and sought a publishing
Macauley
contract for my book which I had completed in 2018. Refer to letter - Austin
2018.
Publishers, London 28th March 2018 / approval of manuscript and contract
I then proceeded to work on a second book development as my intention was to turn the
second book
book into a three part series, which I succeeded in obtaining a contract on the
with Austin macauley Publishers, London in 2019. Refer to letter - Austin Macauley
Publishers, London / approval of manuscript and contract 17th February2020.
EFTA00264383
s7NIPACCOT SOLONE1*
• +J Login (https://sciences.adelaide.edu.au/caslogin?
v( t) returnto=https://sciences.adelaide.edu.au/news/list/2019/10/22/making-high-value-products-
CA ci from-agricultural-waste)
Home (https://sciences.adelaide.edu.au0 / Latest News (Thews/list)
2019 (Thews/list/2019) / 10 (/newsilist12019/10) / 22 (Thews/list/2019/10/22) /
Making high value products from agricultural waste
MenicAL
h
Sc•AenrrcFiC PR•0‘)E0-3 a-area. PRoe 'Mgr - Abet-A(OC ONII
Making Ng
kit Wear( goccy0E
value products
from
agricultural
waste
Posted onOct 22 201 /news/list/2019/10/22). by Sam Le Gallou
(/news/author/Sam%20Le%20Gallou)
Sunscreen from mushroom waste, healthy
skincare products from apples and berries,
and high-tech materials from Brussels sprout
stalks — these are some high value products
that could be first to market from a new $11
million research consortium led by the
University of Adelaide.
South Australian Minister for Innovation and Skills the.Hon. David Pisoni 3)14
/
e
today will launch the Research Consortium Program for Agricultur
Product Development at the4University of Adelaide's Waite campu
V it-Acesci EsOi_oNe-
The Research Consortium aims to turn the high volumes of waste from
new
South Australia's primary production into high-value products for
markets such as pharmaceuticals, cosmetics or packaging.
EFTA00264384
- ri 1 Hen -
_i_Nreizeciont pfteeg
"Investigator-led research aims to deliver long term ben
to the
efits
1
----cci:Jo ccu'. i - v ( tivccRi nac&zi"
sity of Adelaide to
economy and to society. This funding will help the Univer
shape the future of our nation and its knowledge base."
-A .3 4
ject s awarded
-a The 2022 Australian Research Council (ARC) Discovery Pro
to thelfUniversity of Adelaidailare:
Professor Vincent Bulone, School of Agriculture, Foo
'nvestlgate the structure and metabolism of bioa
d and Wine, will
ctive carbohydrates from *-
II brown algae, which will be of interest to the biophar
$621,200 awarded.
maceutical industry.
l Sciences will lead a
Dr Judith Bunder from the School of Mathematica
ing of systems with
team to develop muttiscale mathematical modell
strial research and
complex microscale detail for application in indu
development. $375,000.
Dr Megan Shelden from the
Emeritus Professor Stephen Tyerman and
investigate the missing links in
School of Agriculture, Food and Wine will
salt and water transport in plants. $489,236.
of Civil, Environmental and Mining
Professor Scott Smith in the School
ring will lead a tea m to dev elop a prefabricated structural panel for
Eng inee
lications. $308,000.
current and future infrastructure app
fessor Sar ah Rob erts on from the School of Biomedicine will lead a
Pro
e fertility in livestock animals, and in
team to undertake a project to improv
rare and threatened species. $629,916.
of Biological Sciences, will
Professor Bronwyn Gillanders, School
stability of fish despite volatile
investigate how to enhance population
environmental conditions. $509,000.
Henderson-Sapir from the School of
Professor David Ottaway and Dr Ori
new high-power, simple and robust
Physical Sciences will investigate a
fibr e lase r, whi ch will ope n the door for high-resolution laser
mid -IR
assisted glass 3D-printing. $355,000.
Physical Sciences and Professor
Professor Glenn Solomon, School of
and Electronic Engineering will
Nelson Tansu, School of Electrical
inte gra tion of qua ntu m nan ostructures in optical devices to
investigate the ses
e the effic ienc ies of exis ting optical devices, and create new clas
improv
of quantum photonics. $460,000.
Professor Veronica Soebarto from
Environment (bites•
the School of Architecture and Bui
lt
Lorg111120.htmll will
dge about housing design and indo
or top
A
lead a team to advance knowle
EFTA00264385
Grants pave the
way for further
discovery
Posted on Jan 6 2022 (Thewsroominews/list/2022/01/06). by Crispin
Savage (inewsroominews/author/Crispin%20SavagQ).
T
wenty-two grants totalling $10,189,703 have
been awarded to*University of Adelaide(
researchers from the*Federal Government to
further their work in diverse areas that will
impact people's lives in Australia and globally.
Anton
The University's Deputy Vice-Chancellor (Research), Professor
Middelberg said: "This latest funding will enable University of Adelaide
experts to continue to push the boundaries of research excellence in
diverse fields."
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58 pages
0001
1 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
Case No. 08-CV-80893-CIV-MARRA/JOHNSON
3
4
5 JANE DOE,
6 Plaintiff,
7 vs.
8 JEFFREY EPSTEIN, et al.,
9 Defendants.
10
11
12
13 DEPOSITION OF
Volume 1 of 1
14 Pages 1 through 138
Videotaped
15
16
17 Monday, March 15, 2010
10:13 a.m. - 12:42 p.m.
18 U.S. Legal Support
515 East Las Olas Boulevard, 3rd Floor
19 Fort Lauderdale, Florida 33301
20
21
Stenographically Reported By:
22 Janet L. McKinney, RPR, FPR, CLR
23 Registered Professional Reporter
24 Florida Professional Reporter
25 Certified LiveNote Reporter
0002
1 APPEARANCES:
2 ON BEHALF OF THE PLAINTIFF:
3 FARMER, JAFFE, WEISSING, EDWARDS,
FISTOS & LEHRMAN
4 425 North Andrews Avenue
Suite 2
5 Fort Lauderdale, Florida 33301-3268
6
BY: BRADLEY EDWARDS, ESQ.
7
8 ON BEHALF OF THE DEFENDANT JEFFREY EPSTEIN:
9 BURMAN, CRITTON, LUTTIER &
COLEMAN, LLP
10 303 Banyan Boulevard
Suite 400
11 West Palm Beach, Florida 33401
12
, ESQ.
13
14 ON BEHALF OF OTHER PLAINTIFFS IN RELATED CASES:
15 MERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard
16 Suite 2218
Miami, Florida 33160
17
EFTA00182418
18 BY: STUART S. MERMELSTEIN, ESQ.
19
ON BEHALF OF THE WITNESS:
20
ROBBINS, TUNKEY, ROSS, AMSEL,
21 RABEN & WAXMAN, P.A.
2250 Southwest Third Avenue
22 4th Floor
Miami, Florida 33129
23
24 BY: ALAN S. ROSS, ESQ.
25 Also Present: Sean McGuire, Videographer
U.S. Legal Support
0003
1 INDEX
2
Page
3
Direct Examination By Mr. Edwards 7
4 Cross-Examination By Mr. Mermelstein 111
Redirect Examination By Mr. Edwards 127
5 Recross-Examination By Mr. Mermelstein 133
6
7 Certificate of Oath 137
8 Certificate of Reporter 138
9
10 EXHIBITS
11 PLF'S
12 No. Description Page
13
14 1 Jane Doe 102 v. Jeffrey Epstein 33
15 complaint
16 2A-2G Telephone messages 62
17 3 Handwritten notes 72
18 2H Telephone message 87
19 4 Gawker.com photo with story 127
20
21
22 WITNESS'S
23 No. Description Page
24
25 1 Target letter 4
0004
1 Videotaped deposition taken before JANET L
2 McKINNEY, Registered Professional Reporter, Florida
3 Professional Reporter, Certified LiveNote Reporter and
4 Notary Public in and for the State of Florida at Large
5 in the above cause.
6 (Whereupon, Witness's Exhibit 1 was marked for
7 identification.)
8 VIDEOGRAPHER: We are now on the video record.
9 Today is Monday, the 15th day of March, 2010. The
10 time is 9:13 a.m. (sic). We are here at 515 East
11 Las Olas Boulevard, 3rd Floor, Fort Lauderdale,
12 Florida, for the purpose of taking the videotape
13 deposition of taken in Case Number
14 08-CIV-80893, Jane Doe M. Jeffrey Epstein, et al.
15 The court reporter is Janet McKinney; the
16 videographer is Sean McGuire, both of U.S. Legal
17 Support.
18 Will counsel and all present please introduce
19 yourself and the court reporter will swear the
EFTA00182419
20 witness.
21 MR. EDWARDS: Brad Edwards. I represent the
22 plaintiff, Jane Doe also "Jane Doe"; EW, "EW"; LM,
23 "LM"
24 MR. MERMELSTEIN: Stuart Mermelstein. I
25 represent Jane Doe Numbers 2 through 8.
0005
1 MR. PIKE: Michael Pike on behalf of Jeffrey
2 Epstein.
3 MR. ROSS: And good morning, my name is Alan
4 Ross. I represent the witness,
5 THE REPORTER: Would you raise your right
6 hand, please.
7 Do you solemnly swear or affirm the testimony
8 you're about to give will be the truth, and nothing
9 but the truth, so help you God?
10 THE WITNESS: I do.
11 MR. ROSS: Before the deposition begins and in
12 an effort to streamline the process of getting
13 through this deposition on behalf of the witness we
14 have had marked as Witness Exhibit Number 1 an
15 August 31, 2007 letter from the ' tates
16 Attorney's Office addressed to through
17 her then counsel, Bruce Lyons, which is called a
18 target letter identifying her as a target of a
19 federal Grand Jury investigation in the Southern
20 District of Florida and outlining a number of
21 offenses that were the subject matter of
22 investigation.
23 As a result of that, it is anticipated that
24 some of the questions that may be asked during the
25 course of this deposition she may invoke her Fifth
0006
1 Amendment privilege against self-incrimination.
2 And in order to streamline this we've agreed prior
3 to beginning this that she will simply answer "I
4 refuse to answer." The parties will understand and
5 the record will reflect that she is invoking her
6 Fifth Amendment privilege against
7 self-incrimination.
8 If there is some other privilege,
9 attorney-client privilege or some other objection
10 that I may have to a question, I'll specifically
11 state it. But her answer "I refuse to answer" will
12 be on Fifth Amendment grounds if that's acceptable
13 to everyone.
14 MR. EDWARDS: It's acceptable.
15 MR. MERMELSTEIN: It's acceptable.
16 MR. PIKE: Acceptable.
17 MR. ROSS: Okay. Madam court reporter has
18 already marked the exhibit, and I'll leave that
19 with her.
20 MR. EDWARDS: Okay.
21
22
23
24
25
0007
1 THEREUPON:
2
3 having been first duly sworn or affirmed, was examined
4 and testified as follows:
EFTA00182420
5 DIRECT EXAMINATION
6 BY MR. EDWARDS:
7 Q. Can you tell us your full -- full name.
8 A. .
9 Q. At some point in time you were known as
10 ; is that correct?
11 A. Correct.
12 Q. And when did that change?
13 A. Well, I got married and initially I stayed
14 with my name and then -- because immigration kind of
15 made a mistake of not changing my name when I first
16 came to this country. And at some point when I was
17 removing my conditional residency I made sure that this
18 mistake is corrected. I do not recall exact time when
19 that happened.
20
21
22
23
24
25
0008
1
2
3
4
5
6
7
8
9
10
11
12 A. I was invited by modeling agency on a business
13 visa.
14 Q. What modeling agency?
15 A. Elite Models.
16 Q. And who was the connection at Elite Models
17 that invited you?
18 A. Actually it was my husband. I met him in
19 Europe and at the time he -- he knew that agency and I
20 was modeling in Europe and he showed my pictures and
21 they invited me.
22 Q. How long have you been modeling?
23 A. Since about I was 16 years old.
24 Q. Since 16, so mid-90's? Late 90's?
25 A. Probably around '98, '99, I believe.
0009
1 Q. Okay. And what agencies did you model for in
2 Europe?
3 A. I was with -- in Poland I was with Ricardo Guy
4 that eventually change the name to J and B Models. I
5 was also represented by Ricardo Guy in Milan. Then on
6 my second trip to Milan an agency called Women.
7 I was then represented in Japan by agency --
8 oh, that's -- you just mean Europe or --
9 Q. Well, you can continue.
10 A. Yeah. I was represented in Japan by agency
11 Zucca. I was in South Korea, I do not recall the name
12 of the agency. I was represented in Taiwan by Fashion
13 Management.
14 Q. Okay. And these were all agencies that you
15 worked for or worked with prior to coming to the United
EFTA00182421
16 States?
17 A. Not all of them. Some of them I worked --
18 already been United States and traveling.
19 Q. Okay. But sometime around 2002 you were
20 invited by Elite Models to come to the United States to
21 model?
22 A. Correct.
23 Q. And at the time -- well, where are you from?
24 A. I'm Polish.
25 Q. Okay. So at the time you were a Polish
0010
1 citizen?
2 A. Yes.
3 Q. So in order to come to the United States you
4 needed to get a work visa?
5 A. I was invited actually just to kind of get a
6 feeling if I will be suitable. So I came on a business
7 tourist visa which is, I believe, B1/B2.
a Q. Okay. And where did you first go when you
9 came to the United States, what state?
10 A. Florida.
11 Q. And what city in Florida?
12 A. Miami.
13 Q. And what did you do for your two weeks when
14 you first arrived in Miami, Florida?
15 A. I do not recall.
16 Q. Okay. But did you do any modeling?
17 A. Well, like I would see some photographers, the
18 agency would send me like on all calls to see
19 photographers to kind of introduce me as a model.
20 Q. And why did you make the decision to go with
21 Elite Models in the United States when you already were
22 modeling in --
23 A. Um-hum.
24 Q. -- Europe?
25 A. Well, you know, just to expand it was
0011
1 something that I did. And I decided to take a year off
2 after I graduated from high school and -- you know,
3 just to expand the modeling -- the modeling
4 possibilities, opportunities.
5 Q. Where did you graduate from high school?
6 A. In Warsaw, Poland.
7 Q. What year?
a A. 2002, I believe.
9 Q. And do you have any college? Have you gone to
10 college after that?
11 A. I have an associate degree from Miami Dade
12 College -- Miami Dade College, and I'm pursuing a
13 bachelor degree right now.
14 Q. When did you get your associate's degree from
15 Miami Dade?
16 A. 2008. Summer of 2008.
17 Q. And you're pursuing a bachelor's degree right
18 now?
19 A. Yes.
20 Q. From where?
21 A. Florida International University.
22 Q. In what?
23 A. Accounting.
24 Q. How long have you been in the accounting
25 program?
0012
EFTA00182422
1 A. Since fall 2008.
2 Q. And when do you expect to graduate?
3 A. Fall 2010.
4 Q. Are you a full-time student or part-time?
5 A. I'm a full-time student at this time.
6 Q. When you first arrived in Miami, Florida in
7 fall of 2002 did you decide during that two weeks that
8 you were going to stay permanently?
9 A. No.
10 Q. Okay. Did you go back to Poland?
11 A. Yes, I have. I have -- I went back for
12 Christmas.
13 Q. Okay. Poor question. Going back to 2002 I'm
14 trying to just understand how it was that -- you came
15 over here on a two-week business visa, but eventually
16 you ended up staying for a longer period of time,
17 correct?
18 A. Right.
19 Q. Okay. And how did that come about, just tell
20 me?
21 A. Well, I got romantically involved with my
22 current husband and so when -- you know, we just
23 started dating, we got engaged, and that's how, you
24 know, our relation evolved -- evolved, and eventually,
25 you know, I got married and -- and stayed.
0013
1 Q. Okay. And since coming to the United States
2 have you always lived in Miami, Florida?
3 A. No.
4 Q. All right. Where else have you lived in the
5 United States?
6 A. New York.
7 Q. Where in New York?
8 A. Manhattan.
9 Q. What was the address in Manhattan where you
10 lived?
11 MR. ROSS: I'm going to advise you to invoke
12 privilege.
13 A. I refuse to answer.
14 Q. Okay. Have you -- are you familiar with an
15 address at 301 East 66th Street in New York?
16 A. I refuse to answer.
17 MR. PIKE: May we take a break for a second?
18 May I speak with you?
19 MR. ROSS: Sure.
20 VIDEOGRAPHER: Off the record, 10:22 a.m.
21 (Recess taken at 10:22 a.m.)
22 (Deposition resumed at 10:23 a.m.)
23 VIDEOGRAPHER: On the record, 10:23 a.m.
24 MR. ROSS: Brad, let me just interrupt for a
25 moment.
0014
1 MR. EDWARDS: No problem.
2 MR. ROSS: Just to be sure, when the witness
3 answers "I refuse to answer" to be clear the full
4 statement that she's not saying for the sake of
5 saving time is that she's invoking her Fifth
6 Amendment right against self-incrimination. Just
7 to be clear.
8 MR. EDWARDS: That's what I've understood all
9 along.
10 MR. MERMELSTEIN: That's what I understood.
11 MR. ROSS: Okay, fine. Go ahead.
EFTA00182423
12 MR. EDWARDS: This is just for the sake of
13 brevity --
14 MR. ROSS: Exactly.
15 MR. EDWARDS: -- and let's move it on.
16 BY MR. EDWARDS:
17 Q. All right. So I'm going to ask the question
18 again, I don't remember whether you'd responded yet,
19 but are you familiar with the address in Manhattan
20 301 East 66th Street in New York?
21 A. I refuse to answer.
22 Q. Okay. How long did you live in -- well, what
23 was the first address that you lived in in Miami?
24
25
0015
1 Q. South Shore. Okay.
2 A. Um-hum.
3 Q. Have you ever had your deposition taken
4 before?
5 A. No.
6 Q. Okay. You're doing very well so far. There's
7 a couple rules I didn't explain but mainly because
8 you're doing very well. I just have to wait for you to
9 finish your answer; you have to wait for me to finish
10 my question. We have one court reporter. She can only
11 take down one of us. Give us an answer that we all
12 understand. Nodding of the head or shaking the head
13 are easy to do and I get what you're saying, but she
14 doesn't. Ah-ha or un-ah are things that are commonly
15 said. They look the same on paper.
16 If I ask a bad question which could happen, as
17 already happened and probably will again, just tell me
18 "I don't understand the question," I'll ask it again --
19 A. Okay.
20 Q. -- all right?
21
22
23
24 A. Correct.
25 Q. How long did you live at that address?
0016
1 A I'm sorry, I don't understand your question.
2
3
4 . e , since -- since came ve ere,
5 always stayed there whether being in Miami traveling
6 back and forth, and I live currently at this address.
7 Q. Okay. What was the first time that you moved
8 from that address to live elsewhere?
9 A. I do not recall.
10 Q. Okay. I know that you told me you lived in
11 New York City and we're not going to discuss -- I'm
12 assuming you're not going to answer a lot of questions
13 about New York City, but at what time period did you
14 move there? Was it right after you got here two weeks,
15 a year later? I'm just trying to get a year as to when
16 you moved to New York?
17 MR. ROSS: I'm going to instruct you not to
18 answer.
19 A. I refuse to answer.
20 Q. Okay. Do you know a guy by the name of Jean
21 Luc Brunel?
22 A. I refuse to answer.
EFTA00182424
23 Q. Where are your parents?
24 A. They're in Warsaw, Poland.
25 Q. And since you've been in the United States
0017
1 have they come to the United States?
2 A. Yes, they have visited me.
3 Q. Have they ever met Jeffrey Epstein?
4 A. I refuse to answer.
5 Q. Have they ever met Jean Luc Brunel?
6 A. I refuse to answer.
7 Q. Where are you currently employed?
8 A. I pursue -- I go to school full-time, I do not
9 work.
10 Q. Are you also still in the modeling business
11 though?
12 A. No, I'm not.
13 Q. And when was the last time you did any
14 modeling?
15 A. It would be late spring, early summer of 2006
16 I went on a trip to Taiwan.
17 Q. And why did you stop modeling at that time?
18 A. I wanted -- I always kind of knew that it's
19 something that I'm going to be doing and I just decided
20 to go and pursue a college degree.
21 Q. Okay. Is it something that you ever plan to
22 go back to, modeling?
23 A. No.
24 Q. Are you involved at all with the modeling
25 industry?
0018
1 A. No.
2 Q. I mean, helping to recruit models, helping
3 others to recruit models, anything like that?
4 A. No.
5 Q. Do you ever -- do you currently talk to
6 Mr. Brunel?
7 A. I refuse to answer.
8 Q. When is the last time that you talked to
9 Jeffrey Epstein?
10 A. I refuse to answer.
11 Q. Do you know a woman by the name of Ghislaine
12 Maxwell?
13 A. I refuse to answer.
14 Q. Do you know someone by the name of
16 A. I refuse to answer.
17 Q. Do you know a person named ?
18 A. I refuse to answer.
19 Q. Did Jeffrey Epstein have anything to do with
20 you moving to New York City?
21 A. I refuse to answer.
22 Q. Did you ever live in a place in New York City
23 owned or controlled by Jeffrey Epstein?
24 A. I refuse to answer.
25 Q. Are you familiar with the modeling agency MC
0019
1 Squared?
2 A. I refuse to answer.
3 Q. Do you know of underage females being
4 transported into this country to work for the modeling
5 agency MC Squared?
6 A. I refuse to answer.
7 Q. Do you know of those underage females being
EFTA00182425
8 given work visas and staying at the 301 East 66th
9 Street address?
10 A. I refuse to answer.
11 Q. Can you say whether you have observed
12 Mr. Brunel or Mr. Epstein engaging in sex with underage
13 females?
14 A. I refuse to answer.
15 Q. Do you know where Mr. Brunel lives?
16 A. I refuse to answer.
17 Q. Is it true that Mr. Brunel stays in the 301
18 East 66th address frequently with underage females?
19 A. I refuse to answer.
20 Q. At what point were you hired to work for
21 Mr. Epstein?
22 MR. PIKE: Form.
23 MR. EDWARDS: You can still answer the
24 question. Mr. Pike is making a legal objection.
25 A. I refuse to answer.
0020
1 Q. And how did -- how did it come about that you
2 began working with Jeffrey Epstein?
3 MR. PIKE: Form.
4 A. I refuse to answer.
5 Q. What did Jeffrey Epstein pay you in salary?
6 MR. PIKE: Form.
7 A. I refuse to answer.
8 Q. What was the time period that you worked for
9 him?
10 A. I refuse to answer.
11 Q. Why did you stop working for him?
12 MR. PIKE: Form.
13 A. I refuse to answer.
14 Q. What initially were you hired to do?
15 A. I refuse to answer.
16 MR. PIKE: Form.
17 Q. Has Jeffrey Epstein ever paid you to stay
18 quiet or keep quiet about what went on in his house?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. Have you talked to or
about the things that went on in Jeffrey
23 Epstein's house?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0021
1 Q. Did you sign a confidentiality agreement with
2 Jeffrey Epstein?
3 A. I refuse to answer.
4 MR. PIKE: Form.
5 Q. Did that confidentiality agreement outline
6 what you should say to authorities should he be caught
7 with underage females?
8 MR. PIKE: Form.
9 A. I refuse to answer.
10 Q. Is there another book or manual or written
11 memorialization of what you, as an employee of Jeffrey
12 Epstein, should do if confronted by law enforcement?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Are you invoking your Fifth Amendment right
16 because you believe you could be prosecuted?
17 MR. ROSS: Invoke.
18 A. I refuse to answer.
EFTA00182426
19 Q. Are you also invoking because you're scared to
20 testify against Jeffrey Epstein?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. When did you first learn that Jeffrey Epstein
24 had a sexual obsession for underage females?
25 A. I refuse to answer.
0022
1 MR. PIKE: Form.
2 Q. Isn't it true that you have seen Jeffrey
3 Epstein sexually interacting with females as young as
4 12 years old?
5 A. I refuse to answer.
6 MR. PIKE: Form.
7 Q. Is it true that you have observed Jeffrey
a Epstein's sexual obsession to include the age range 12
9 to 17?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Have you ever had sex with Jeffrey Epstein?
13 A. I refuse to answer.
14 MR. PIKE: Form.
15 Q. Have you ever been paid for sex with Jeffrey
16 Epstein?
17 MR. PIKE: Form.
18 A. I refuse to answer.
19 Q. Do you know if had sex with
20 Jeffrey Epstein when she was underage?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. What have you been told about Jeffrey
24 Epstein's sexual obsession with underage minor
25 children?
0023
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Isn't it true that Jeffrey Epstein interacted
4 sexually with underage minors on an everyday basis?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. And most of the time Mr. Epstein would
8 interact with underage minors at least two times a day;
9 is that true?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Can you explain to the jury how Mr. Epstein
13 would access new underage minor females for sex every
14 day?
15 MR. PIKE: Form.
16 A. I refuse to answer.
17 Q. How many assistants did Jeffrey Epstein hire
18 to bring him underage minor females for sex?
19 A. I refuse to answer.
20 MR. PIKE: Form.
21 Q. Were you one of those assistants that helped
22 to bring him underage minor females?
23 MR. PIKE: Form.
24 A. I refuse to answer.
25 Q• I know that the laws in Poland are probably
0024
1 different than they are here, but are you familiar with
2 the Florida Statutes that protect children against
3 sexual offenders or sexual predators?
EFTA00182427
4 MR. ROSS: Invoke.
5 A. I refuse to answer.
6 Q. Let me just read you the lewd or lascivious
7 molestation statute and then I'm going to ask you some
8 questions about it.
9 It says: "A person who intentionally touches
10 in a lewd or lascivious manner the breasts, genitals,
11 genital area or buttocks or the clothing covering them
12 of a person less than 16 years of age or forces or
13 entices a person under 16 years of age to so touch the
14 perpetrator, commits lewd or lascivious molestation, a
15 second degree felony."
16 After hearing that statute isn't that
17 something -- isn't that a crime that you know
18 Mr. Epstein to have committed on an everyday basis
19 while you were working for him?
20 MR. PIKE: Form.
21 A. I refuse to answer.
22 Q. And that's a statute that he violated with
23 more than 100 underage females; is that true?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0025
1 Q. When did you become aware that Mr. Epstein was
2 a child molester?
3 MR. PIKE: Form.
4 A. I refuse to answer.
5 Q. Have you ever seen him with a female under the
6 age of 12?
7 MR. PIKE: Form.
8 A. I refuse to answer.
9 Q. Have you ever known Jeffrey Epstein to have
10 sex with an adult?
11 MR. PIKE: Form.
12 A. I refuse to answer.
13 Q. Does he -- is he sexually attracted to adults?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. When was the first time you learned of
17 Mr. Epstein getting a massage from an underage minor
18 female?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. I realize some of these questions may sound
22 repetitive but during this case we've learned of key
23 terms that different people on Mr. Epstein's let's say
24 payroll or inner circle recognize or talk about. So
25 when I talk about "massages", do you know what that
0026
1 term means?
2 MR. PIKE: Form.
3 A. I refuse to answer.
4 Q. Isn't "massage" the word that was told by
5 Jeffrey Epstein to all of his employees to refer to
6 whatever acts he engages in with underage females in
7 his bedroom?
8 MR. PIKE: Form.
9 A. I refuse to answer.
10 Q. At this point -- were you -- were you ever in
11 the bedroom with him when he was engaging in sexual
12 acts with underage females and calling them "massages"?
13 MR. PIKE: Form.
14 A. I refuse to answer.
EFTA00182428
15 Q. Did you ever participate in any of the sexual
16 acts that Jeffrey Epstein was having with underage
17 females?
18 MR. PIKE: Form.
19 A. I refuse to answer.
20 Q. Now, just so that the record is clear there is
21 not a single piece of evidence that ever indicates that
22 you were involved with underage females, I'm not even
23 implying that and I realize that you invoking it may --
24 may give the wrong light and that's not -- that's not
25 my intention, so -- but were you ever aware of
participating in sex with underage females?
2 A. I refuse to answer.
3 Q. Have you read the police reports related to
4 the criminal investigation into Mr. Epstein?
5 A. I refuse to answer.
6 Q. And you're aware of this 87-page police report
7 that details numerous females that indicate that they
8 were involved sexually with Mr. Epstein when they were
9 minors?
10 A. I refuse to answer.
11 MR. PIKE: Form.
12 Q. Did anyone instruct you to use the code word
13 "massage"?
14 A. I refuse to answer.
15 Q. And when referring to these underage minor
16 females that would come over to Mr. Epstein's house did
17 anybody also tell you to use the term "work"?
18 A. I refuse to answer.
19 MR. PIKE: Form.
20 Q. Meaning when somebody would call to schedule
21 one of these underage females for a massage isn't it
22 true that they would say "It's time to come to work"
23 and schedule a specific appointment?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0028
1 Q. Is there a book or manual or is it written
2 anywhere that the -- that sex with underage minors is
3 to be referred to as a "massage"?
4 A. I refuse to answer.
5 MR. PIKE: Form.
6 Q. Were there ever team meetings, for lack of a
7 better word, where Jeffrey Epstein and possibly
8 Ghislaine Maxwell, , yourself, would talk
9 about this organization of obtaining underage girls for
10 Jeffrey Epstein for sex?
11 MR. PIKE: Form.
12 A. I refuse to answer.
13 Q. What methods does Jeffrey Epstein use to gain
14 access to underage minor females for sex?
15 MR. PIKE: Form.
16 A. I refuse to answer.
17 Q. What is your understanding of Jeffrey
18 Epstein's involvement with the modeling industry?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. Have you ever modeled for MC Squared?
22 MR. PIKE: Form.
23 A. I refuse to answer.
24 Q. Has Jeffrey Epstein ever promised you anything
25 related to a modeling career?
EFTA00182429
0029
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Have you ever talked to Jean Luc Brunel about
4 modeling?
5 A. I refuse to answer.
6 Q. Have you ever talked to Jean Luc Brunel about
7 his desire to have sex with underage females?
8 A. I refuse to answer.
9 Q. Isn't it true that Jean Luc Brunel has been in
10 trouble for years for having sex with underage minors
11 in Europe?
12 A. I refuse to answer.
13 Q. Are you familiar with The McIntyre Reports?
14 A. I refuse to answer.
15 Q. Okay. Are you familiar with reports done on
16 modeling agencies back in the 80's and 90's related to
17 agency owners having sex with underage minors?
18 MR. ROSS: Answer the question.
19 A. No, I'm not.
20 Q. Okay. Did you ever hear of Jean Luc Brunel's
21 reputation for having sex with underage girls?
22 MR. ROSS: Invoke.
23 A. I refuse to answer.
24 Q. Do you know how Jean Luc Brunel knows Jeffrey
25 Epstein?
0030
1 A. I refuse to answer.
2 MR. PIKE: Form.
3 Q. Isn't their connection the obsession for
4 underage minor females?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. Based on your observations of Jeffrey Epstein
8 would you categorize his obsession for underage minor
9 females as an addiction?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Isn't it true that Ghislaine Maxwell delivers
13 underage minor females to Jeffrey Epstein?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. Have you ever had a sexual relationship with
17 Ghislaine Maxwell?
18 A. I refuse to answer.
19 Q. Do you know what Ghislaine Maxwell does in
20 general for Jeffrey Epstein?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. Have you seen photographs of underage minor
24 females in Jeffrey Epstein's patrol -- control or
25 possession?
0031
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Were there surveillance cameras, hidden
4 surveillance cameras inside Jeffrey Epstein's home?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. Did those surveillance cameras capture
8 underage minor females naked?
9 MR. PIKE: Form.
10 A. I refuse to answer.
EFTA00182430
11 Q. And didn't Jeffrey Epstein and Ghislaine
12 Maxwell watch those surreptitiously obtained videos of
13 underage minor females?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. And those videos and photographs of underage
17 minor females were saved on Jeffrey Epstein's computers
18 in his house, right?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. Have you seen those photographs and videos on
22 Jeffrey Epstein's computers?
23 MR. PIKE: Form.
24 A. I refuse to answer.
25 Q. Who have you talked to related to the criminal
0032
1 investigation into Jeffrey Epstein?
2 A. I refuse to answer.
3 MR. PIKE: Form.
4 MR. ROSS: In addition, attorney-client
5 privilege.
6 Q. And I certainly would -- do not want to know
7 anything you talked to your attorney about, I
8 apologize.
9 A. (Nods.)
10 Q. Why was it that you were named as a
11 co-conspirator of Jeffrey Epstein's in the
12 non-prosecution agreement?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Do you feel like a victim of Jeffrey
16 Epstein's?
17 MR. PIKE: Form.
18 A. I refuse to answer.
19 Q. Do you feel like Jeffrey Epstein brainwashed
20 you to some extent?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. Do you feel any remorse for any role that you
24 may have played in having underage minor females at
25 Jeffrey Epstein's house for him to molest them?
0033
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. Have you known Ghislaine Maxwell and Jeffrey
4 Epstein to keep sex slaves?
5 A. I refuse to answer.
6 Q. Do you know somebody named ?
7 A. I refuse to answer.
8 Q. Have you met ?
9 A. I refuse to answer.
10 MR. EDWARDS: All right. Let me go ahead and
11 mark as -- as Plaintiff's Exhibit 1 a lawsuit that
12 was filed by Bob Josefsberg on behalf of Jane Doe
13 102 v. Jeffrey Epstein just for the purposes of
14 asking the witness some questions.
15 MR. ROSS: I've seen it.
16 (Whereupon, Plaintiff's Exhibit 1 was marked
17 for identification.)
18 Q. Have you ever read the lawsuit Jane Doe 102 M.
19 Jeffrey Epstein?
20 A. I refuse to answer.
21 Q. In the lawsuit it indicates the plaintiff was
EFTA00182431
22 15 years old when Ghislaine Maxwell and Jeffrey Epstein
23 had a threesome with this underage minor female. Are
24 you aware of that?
25 MR. PIKE: Form.
0034
1 A. I refuse to answer.
2 Q. And Jeffrey Epstein and/or Ghislaine Maxwell
3 obtained and purchased passports for 15-year-old Jane
4 Doe 102 to transport her to Palm Beach, New York City,
5 Santa Fe, Los Angeles, San Francisco, St. Louis, as
6 well as Europe, the Caribbean, and Africa; are you
7 aware of that?
8 A. I refuse to answer.
9 MR. PIKE: Form.
10 Q. It's also alleged that Jeffrey Epstein in
11 addition to molesting Jane Doe 102 along with Ghislaine
12 Maxwell forced her to have sex with other models,
13 actresses, and celebrities?
14 A. I refuse to answer.
15 MR. PIKE: Form.
16 Q. It also indicates that Jeffrey Epstein
17 transported other minor girls from Turkey, the Czech
18 Republic, Asia, and other countries. Are you aware of
19 that?
20 MR. PIKE: Form.
21 A. I refuse to answer.
22 Q. Is Jeffrey Epstein involved in the
23 international child sex trade?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0035
1 Q. Is Jean Luc Brunel his partner in that
2 international child sex trade?
3 MR. PIKE: Form.
4 A. I refuse to answer.
5 Q. Are you aware that after -- that Jeffrey
6 Epstein forced Jane Doe 102 to have sex with other
7 adult male peers including royalty, politicians,
8 academicians, businessmen and/or other professional and
9 personal acquaintances of Jeffrey Epstein's?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Is that something that he did with girls other
13 than Jane Doe 102?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. Aren't you familiar with Jeffrey Epstein's
17 practice of pimping out underage minor females to other
18 people that have the same sexual obsession with
19 underage minors?
20 MR. PIKE: Form.
21 A. I refuse to answer.
22 Q. And doesn't he benefit financially from that
23 sex trade?
24 MR. PIKE: Form.
25 A. I refuse to answer.
0036
1 Q. Jane Doe 102 ultimately escaped from him and
2 left to Australia, is that your understanding?
3 A. I refuse to answer.
4 MR. PIKE: Form.
5 Q. Have you ever spoken with Jane Doe 102?
6 A. I refuse to answer.
EFTA00182432
7 Q. On one of Epstein's birthdays a friend of
8 Jeffrey Epstein sent to him 12 -- three 12-year-old
9 girls from France who spoke no English for Epstein to
10 sexually exploit and abuse and after doing so he sent
11 them back to France the next day. Are you familiar
12 with that?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. Isn't that something that is fairly common for
16 Mr. Epstein?
17 A. I refuse to answer.
18 MR. PIKE: Form.
19 Q. Who are the friends that send to Jeffrey
20 Epstein underage minor females for his birthday so that
21 he can abuse?
22 A. I refuse to answer.
23 MR. PIKE: Form.
24 Q. Is one of those friends Jean Luc Brunel?
25 A. I refuse to answer.
0037
1 Q. Have you ever met Prince Andrew?
2 A. I refuse to answer.
3 Q. Has Prince Andrew been involved with underage
4 minor females to your knowledge?
5 A. I refuse to answer.
6 Q. Have you ever met Alan Dershowitz?
7 A. I refuse to answer.
8 Q. When Alan Dershowitz stays at Jeffrey
9 Epstein's house isn't it true that he has been at the
10 house when underage minor females have been in the
11 bedroom with Jeffrey Epstein?
12 A. I refuse to answer.
13 Q. Has -- are you familiar with the media
14 publication or online resource RadarOnline?
15 A. I refuse to answer.
16 Q. Is that something that you assisted
17 Mr. Epstein with when he purchased RadarOnline?
18 A. I refuse to answer.
19 Q. And do you know his business partner in that
20 endeavor?
21 A. I refuse to answer.
22 Q. Isn't it also true that he used RadarOnline as
23 another way to gain access to underage minor females
24 for sex?
25 MR. PIKE: Form.
0038
1 A. I refuse to answer.
2 Q. Have you been to all of Jeffrey Epstein's
3 properties?
4 MR. PIKE: Form.
5 A. I refuse to answer.
6 Q. Certainly you've been to the property at 358
7 El Brillo Way, correct?
8 MR. PIKE: Form.
9 A. I refuse to answer.
10 Q. Have you been to his property in Manhattan?
11 A. I refuse to answer.
12 MR. PIKE: Form.
13 Q. And have you been to his island in -- it was
14 Little St. James, I believe he calls it Little
15 St. Jeff's now?
16 MR. PIKE: Form.
17 A. I refuse to answer.
EFTA00182433
18 Q. And have you witnessed underage child sex
19 orgies on that island?
20 MR. PIKE: Form.
21 A. I refuse to answer.
22 Q. Do you know a female named Jeletzia?
23 A. I refuse to answer.
24 Q. Do you know where Jeletzia lives these days?
25 A. I refuse to answer.
0039
1 Q. What is your understanding of
2 role in Jeffrey Epstein's life?
3 A. I refuse to answer.
4 MR. PIKE: Form.
5 Q. Isn't it true that she gets paid just to bring
6 him underage minor females for sex?
7 MR. PIKE: Form.
8 A. I refuse to answer.
9 Q. And additionally, she schedules the
10 appointments for underage minor females for him to
11 molest?
12 A. I refuse to answer.
13 MR. PIKE: Form.
14 Q. You know ?
15 A. I refuse to answer.
16 Q. Does she still work for Ghislaine Maxwell?
17 A. I refuse to answer.
18 Q. Was she an underage minor child victim of
19 Jeffrey Epstein's?
20 A. I refuse to answer.
21 Q. Through discovery we've talked to numerous
22 witnesses about, you know, Jeffrey Epstein and people
23 that work for him. I don't know if you'll be able to
24 answer any of these questions but I'll ask them anyway
25 one at a time.
0040
1 Is somebody who travels with
2 Jeffrey Epstein?
3 MR. PIKE: Form.
4 A. I refuse to answer.
5 Q. And when Jeffrey Epstein is coming to town
6 doesn't he call his number one assistant?
7 MR. PIKE: Form.
a A. I refuse to answer.
9 Q. And at some point in time, it looks like in
10 early 2005 or late 2004, you were also an assistant of
11 Jeffrey Epstein's, correct?
12 MR. PIKE: Form.
13 A. I refuse to answer.
14 Q. And how was it that you transitioned from
15 being involved in modeling to being an employee of
16 Jeffrey Epstein?
17 MR. PIKE: Form.
18 A. I refuse to answer.
19 Q. Other than arranging for underage minor
20 females to come to Jeffrey Epstein's house did you do
21 anything else for Jeffrey Epstein?
22 MR. PIKE: Form.
23 A. I refuse to answer.
24 Q. Did you ever fly on Jeffrey Epstein's
25 airplane?
0041
1 A. I refuse to answer.
2 Q. Did you witness Jeffrey Epstein abuse --
EFTA00182434
3 sexually abusing underage minor females on his
4 airplane?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. Did you know that it was illegal for Jeffrey
8 Epstein to interact sexually with underage minor
9 females?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Did you ever object to Jeffrey Epstein
13 interacting sexually with underage minor females?
14 MR. PIKE: Form.
15 A. I refuse to answer.
16 Q. Would Jeffrey Epstein get angry at you if you
17 did not have an appointment set for him with an
18 underage minor female?
19 MR. PIKE: Form.
20 A. I refuse to answer.
21 Q. Has Jeffrey Epstein contacted you in the last
22 year?
23 A. I refuse to answer.
24 MR. PIKE: Form.
25 Q. Has contacted you within the last
0042
1 year?
2 A. I refuse to answer.
3 Q. Has anybody that is associated with Jeffrey
4 Epstein's party contacted you in the last year?
5 MR. PIKE: Form.
6 A. I refuse to answer.
7 Q. By that I mean to include Ghislaine Maxwell,
8 , any of these people, have they contacted
9 you within the last year?
10 MR. PIKE: Form.
11 A. I refuse to answer.
12 Q. Are you familiar with the names of some of the
13 underage minor females?
14 A. I refuse to answer.
15 Q. Are you familiar with LM?
16 A. I refuse to answer.
17 Q. Do you remember what LM looked like?
18 A. I refuse to answer.
19 Q. Are you familiar with EW?
20 A. I refuse to answer.
21 Q. Do you remember what EW looked like?
22 A. I refuse to answer.
23 Q. Are you familiar with Jane Doe?
24 A. I refuse to answer.
25 Q. These are all females that were underage minor
0043
1 females that Jeffrey Epstein interacted with sexually
2 during a time when you were working for him; isn't that
3 true?
4 A. I refuse to answer.
5 MR. PIKE: Form.
6 Q. And LM was somebody that went over to Jeffrey
7 Epstein's house and was molested at a young age by him
8 more than 100 times; is that true?
9 MR. PIKE: Form.
10 A. I refuse to answer.
11 Q. And EW was also somebody who went over to
12 Jeffrey Epstein's house when she was between 14 and
13 16 years old more than a hundred times; isn't that
EFTA00182435
14 true?
15 MR. PIKE: Form.
16 A. I refuse to answer.
17 Q. And Jane Doe was somebody that went to Jeffrey
18 Epstein's house more than 15 times to be molested by
19 Jeffrey Epstein when she was 14 and 15 years old; is
20 that true?
21 MR. PIKE: Form.
22 A. I refuse to answer.
23 Q. Is it also true that LM brought to Jeffrey
24 Epstein's house between 50 and 75 other underage minor
25 females for Jeffrey Epstein to molest?
0044
1 A. I refuse to answer.
2 MR. ROSS: Form.
3 Q. Are you aware of Jeffrey Epstein's for lack of
4 a better word "ritual" with these underage minor
5 females in his bedroom?
6 MR. PIKE: Form.
7 A. I refuse to answer.
a Q. Wouldn't it generally begin with Jeffrey
9 Epstein placing a call to or yourself and
10 telling you that he's going to be in town at the Palm
11 Beach mansion?
12 MR. PIKE: Form.
13 A. I refuse to answer.
14 Q. And then isn't there a list of underage minor
15 females stored in the computer system?
16 MR. PIKE: Form.
17 A. I refuse to answer.
18 Q. And that computer system is interconnected
19 from his New York home, his New Mexico home, his
20 island, his home in France, and West Palm Beach; is
21 that correct?
22 MR. PIKE: Form.
23 A. I refuse to answer.
24 Q. And have you seen that list of underage minor
25 females stored in the computer system?
0045
1 MR. PIKE: Form.
2 A. I refuse to answer.
3 Q. And isn't it true there are over a thousand
4 girls at any given time between the age range of 12 and
5 17 all of which have been molested by Jeffrey Epstein?
6 MR. PIKE: Form.
7 A. I refuse to answer.
a Q. And when Mr. Epstein would call and tell you
9 the time that he was going to be in town it would then
10 be your job to get an underage minor female to his
11 house and set a specific appointment for that person;
12 is that correct?
13 MR. PIKE: Form.
14 A. I refuse to answer.
15 Q. And he would tell you the exact time of day
16 that he wanted his two or three appointments to molest
17 underage minor females?
18 MR. PIKE: Form.
19 A. I refuse to answer.
20 Q. And you would go into the computer system and
21 call the person that he told you he wanted to see for
22 that day
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
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
EFTA00738470
ROTHSTEIN ROSENFELDT ADLER
Attorneys for Plaintiff
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Tel: (954) 522-3456
Fax: (954) 527-8663
Email: bedwards@rra-law.com
B
BRAD EDWARDS, ESQ.
Florida Bar No.: 542075
cc: Esquire Court Reporters
EFTA00738471
DataSet-10
Unknown
2 pages
From: "Daniel J. Kaiser"
To:'
Cc: ' "William H. Kaiser"
Subject: Re: Epstein case, SDNY
Date: Fri, 26 Jul 2019 09:33:15 +0000
I am in Boston for a deposition but can speak between 1:00 and 2:00 if that works. My cell is
Dan
Dan
Daniell. Kaiser
Kaiser Saurborn & Mair, P.C.
On Jul 25, 2019, at 11:38 PM, > wrote:
Dan, Kimberly,
Following up on our discussions regarding we were wondering if you have time for a brief call tomorrow, or if
not, at your earliest convenience next week? We don't expect to take long but do want to be quickly in touch when
you're available.
thank you,
Assistant U.S. Attorney
Southern District of New York
From: Daniell. Kaiser
Sent: Sunday, July 14, 2019 08:05
To
Cc: William H. Kaiser 1
Subject: Re: Epstein case, SDNY
Thanks to all of you for handling the meeting with .o professionally. We greatly appreciate it.
Dan
Daniell. Kaiser
Kaiser Saurborn & Mair, P.C.
EFTA00068295
On Jul 14, 2019, at 12:09 AM, > wrote:
Team — following up on our meeting yesterday, I wanted to make sure you all have the contact info for our full team.
My colleagues and care also working on the case, and they're copied here and we're all
reachable at these email addresses or by phone anytime at:
We greatly appreciated being willing to talk with us, and I expect we'll be in touch again in the coming
weeks. And of course if anything comes up that you want to reach out to us about, please don't hesitate at all.
thank you,
Assistant U.S. Attorney
Southern District of New York
EFTA00068296
DataSet-10
Unknown
1 pages
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
B.B Case No: 502008CA037319)OOOCMB AB
Plaintiff,
vs.
JEFFREY EPSTEIN
Defendant.
TAKING DEPOSITION
PLAINTIFF'S RE-NOTICE OFsmith
(Coordinated with Mr. Gold 's attornev's office)
RNEY WILL TAKE THE DEPOSITION OF:
PLEASE TAKE NOTICE THAT THE UNDERSIGNED' ATTO
DATE AND TIME: LOCATION:
NAME:
April 19, 2010 Prose Court Reporting, 250 S.
Charles Gerald Goldsmith
9:30 AM Australian Avenue, Suite
1500, West Palm Beach, FL
33401
by law to take depositions in
upon an oral examination before a Notary Public or officer authorized
to day until completed. The
the State of Florida. The oral examination will continue from day
trial or are being taken for such
depositions are being taken for purposes of discovery, for use at
other purposes as are permitted under the Rules of the Court.
true and correct copy of this Notice was mailed this ZO_
WE HEREBY CERTIFY that aerger,
day of February, 2010 to: Jack A. GoldbEsq., 250 Australian Avenue, Suite 1400, West Palm
Avenue South, Suite 1400, West Palm
Beach, FL 33401; Bruce B. Reinhart Esq., 250 Australian
Banyon Boulevard, Suite 400, West
Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 303
PA, 501 s. Flagler Drive, Suite
Palm Beach, FL 33401; Jeffiey Fisher, Esq., Fisher & Bendeck,
450, West Palm Beach, FL 33401.
LEOPOLD--KUVIN, P.A.
2925 PGA Boulevard, Suite 200
each Gardens, FL 33410
By:
near .Ku
Florida Bar No: 089737
EFTA00723894
DataSet-10
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2 pages
Massachusetts law:
M.G.L.A. 233 § 45
§ 45. Deposition for use in another state
A person may be summoned and compelled, in like manner and under the same penalties as are provided for a
witness before a court, to give his deposition in a cause pending in a court of any other state or government. Such
deposition may be taken before a justice of the peace or a notary public in the commonwealth, or before a
commissioner appointed under the authority of the state or government in which the action is pending. If the
deposition is taken before such commissioner, the witness may be summoned and compelled to appear before him by
process from a justice of the peace or a notary public in the commonwealth.
Florida law
West's F.S.A. § 92.251
92.251. Uniform Foreign Depositions Law
(1) This section may be cited as the "Uniform Foreign Depositions Law."
(2) Whenever any mandate, writ or commission is issued out of any court of record in any other state, territory,
district, or foreign jurisdiction, or whenever upon notice or agreement it is required to take the testimony of a witness
or witnesses in this state, witnesses may be compelled to appear and testify in the same manner and by the same
process and proceeding as may be employed for the purpose of taking testimony in proceedings pending in this state.
(3) This section shall be so interpreted and construed as to effectuate its general purposes to make uniform the law of
those states which enact it.
Greenlight Fin. Servs., Inc. v. Union Am. Mortgage, Inc., 971 So. 2d 983, 985
(Fla. Dist. Ct. App. 2008)
Under UFDL, as adopted by Florida in section 92.251 whenever a litigant desires to depose a witness residing in
another state, that litigant must first secure the appointment of a commissioner from the court where the litigation
originates. See Freedom Newspapers. Inc., 507 So.2d at 1183. The foreign litigant may then apply to the court
having personal jurisdiction over the witness for the process necessary to secure the attendance of the witness. Id.
(citing Travelers Indem. Co. v. Hill, 388 So.2d 648 (Fla. 5th DCA 1980)). Florida's UFDL specifically provides, in
pertinent part, as follows:
(2) Whenever any mandate, writ or commission is issued out of any court of record in any other state, territory,
district, or foreign jurisdiction, or whenever upon notice or agreement it is required to take the testimony of a witness
or witnesses in this state, witnesses may be compelled to appear and testify in the same manner and by the same
process and proceeding as may be employed for the purposes of taking testimony in proceedings pending in this
state.
(Emphasis added). This means that the court where the deposition actually takes place, in this case, Florida,
enjoys all necessary powers of enforcement as if the action were taking place in Florida, and the laws of
Florida govern any proceedings incident to the deposition. See Freedom Newspapers, Inc.. 507 So.2d at 1184.
The trial court in this case, therefore, erred in its determination that it was without jurisdiction to entertain the
discovery objections associated with the subject depositions in accordance with Florida law. The UFDA proceeding
before the court below is essentially a separate action, distinct from, although ancillary to, the underlying cause of
action pending in California. See America Online, Inc. v. Anonymous Publicly Traded Co.. 261 Va. 350, 542
EFTA01206918
S.E.2d 377. 380 (2001)• Warlord v. Childers. 642 S.W.2d 63.65 (Tex.AnD.1982). Indeed, only the court below has
jurisdiction to enforce the Florida subpoena duces tecum at issue against this Florida non-party witness.
Travelers Indem. Co. v. Hill, 388 So. 2d 648, 650 (Fla. Dist. Ct. App. 1980)
Ohio, like Florida, has also adopted the Uniform Foreign Deposition Act. Under these circumstances, when a Florida
litigant needs testimony of a witness in Ohio, the first step in the proceedings is to secure the appointment of a
commissioner by the Florida court. Application is then made to the Ohio court for the process necessary to secure the
attendance of the witness. It seems to us that under ordinary circumstances the appointment of a commissioner is a
perfunctory matter barring some showing to the contrary by the adverse party.
EFTA01206919
DataSet-10
Unknown
180 pages
Original Transcript
IN THE CIRCUIT COURT OF THE FIFrEENTII JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL, DIVISION
L.M.,
Plaintiff,
vs. CASE No.
502008CA0280513OOOCMB AB
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME H
October, 20, 2009
10:10 a.m.
515 N. Flagler Drive
Suite 200-P
West Palm Beach, Florida 33401
Reported By: Teresa Whalen, RPR, FPR, Notary Public, State of Florida
Toll Free: 866.709.8777
Facsimile: 561.394.2621
S Suite 600
4440 PGA Boulevard
ESQUIRE •n Al noel. Vall•Compny
Palm Beach Gardens, FL 33410
wvnv.esoulresolutIons.com
EFTA00182476
•
•
•
EFTA00182477
131
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
CASE No.502008CA028051XXXXMB AB
L.M.,
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
VOLUME II
Tuesday, October, 20, 2009
10:10 - 3:30 p.m.
D15 N. Flagler Drive, Suite 200-P
West Palm Beach, Florida 33401
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
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
way.esquIresoludons.com
EFTA00182478
- Volume II October 20, 2009
132
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CV-80119-CIV-MARRA/JOHNSON
4 JANE DOE NO. 2,
Plaintiff,
-vs-
7 JEFFREY EPSTEIN,
Defendant.
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
515 N. Flagler Drive, Suite 200-P
17
West Palm Beach, Florida 33401
18
19
20
21 Reported By:
Teresa Whalen, RPR, FPR
22 Notary Public, State of Florida
West Palm Beach Office Job 11118991
23 Phone:
24
25
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQLTLRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutlons.com
EFTA00182479
- Volume II October 20, 2009
133
• APPEARANCES:
On behalf of the Defendant:
ROBERT D. CRITTON, JR., ESQUIRE
BURMAN CRITTON LUTTLER & COLEMAN, LLP
303 Banyan Boulevard, Suite 400
West Palm Beach, Florida 33401
Phone:
7 On behalf of Plaintiff L.M.:
BRADLEY J. EDWARDS, ESQUIRE
CARA L. HOLMES, ESQUIRE
ROTHSTEIN ROSENFELDT ADLER
401 E. Las Olas Boulevard, Suite 1650
10 Fort Lauderdale, Florida 33394
Phone:
11
12 On behalf of the Witness:
13 BRUCE E. REINHART, ESQUIRE
LAW OFFICE OF BRUCE E. REINHART
• 14 250 S. Australian Avenue, Suite 1400
West Palm Beach, Florida 33401
15 Phone:
16
17 On behalf of Defendants/Jane Does 2 - 8:
18 STUART S. MERMELSTEIN, ESQUIRE
MERMELSTEIN & HOROWITZ, P.A.
19 18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
2C Phone:
21 On behalf of Plaintiff in related Case No. 08-80811
22 JACK HILL, ESQUIRE (Partially via speakerphone)
SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY
23 2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
24 Phone:
25
Toil Free: 866.709.8777
• 0 Facsimile: 561.394.2621
Suite 600
4440 PGA Boulevard
ESQUIRE Palm Beach Gardens, FL 33410
www.esquIresolutions.corn
EFTA00182480
- Volume II October 20, 2009
134
1
2
3 INDEX
4
5
6 WITNESS: DIRECT CROSS REDIRECT RECROSS
7
8
9 BY MR. EDWARDS: 5 190
10 BY MR. MERMELSTEIN: 135 208
11 BY MR. HILL: 156
12 BY MR. CRITTON: 173
13
14
15 EXHIBITS
16
17
18 NUMBER DESCRIPTION PAGE
19 DEPENDANT'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
Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.corn
EFTA00182481
- Volume II October 20, 2009
135
• 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. Hill joined the proceedings in person.)
9 CROSS (
10 BY MR. MERMELSTEIN:
11 O Good afternoon. Is it all right if I call you
12
13 A Yes.
• 14
15
Q Okay. My name is Stuart Mermelstein, I also
represent some plaintiffs in these cases, and it is my
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 weal. Lu work your
22 regular schedule at 358 El Brillo Way; is that correct?
23 A Yes.
24 • So you were working basically --
25 MR. CRITTON: She's not finished.
• 0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 000
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
wurw.esquiresolutions.com
EFTA00182482
- Volume II October 20, 2009
136
1 BY MR. MERMELSTEIN:
2 Q I'm sorry. Go ahead.
3 MR. REINHART: Do you need to expand on your
4 answer?
5 BY MR. MERMELSTEIN:
6 Q 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 A Yee.
15 Q 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 Q Okay. It didn't matter whether you there at
20 eight or nine when he was not there, correct?
21 A No.
22 Q 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 not
25 there during the time he was in jail from when he would
Toll Free: 866.709.8777
CIO Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beath Gardens, FL 33410
www.esquiresolutions.com
EFTA00182483
- Volume II October 20, 2009
137
• 2
come there before he went to jail?
A When he was in jail?
3 • Yes.
4 A I clean the house.
5 Q 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 linens.
12 Oh. Inventory of the linens?
13 A Inventory.
• 14
15
Q Okay.
do to fill the time?
So you did that. And what else did you
16 A Wash the clothes that was in storage, you
17 know.
18 Q 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 of Lhe house?
22 A No. In the house.
23 Q In the house. Okay. So even if they hadn't
24 been worn, you washed them, correct?
25 A And press them.
• 0 Toll Free: 866.709.8777
Facsimile: 561.394.2621
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
EFTA00182484
- Volume II October 2C, 20C9
138
1 MR. CRITTON: Form.
2 THE WITNESS: Yes.
3 BY MR. MERMELSTE:N:
4 Q What other type of things did you do while he
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 0 Okay.
11 A If there are orchids or plants in the house,
12 then I attend to it.
13 Q I guess my question is what kind of projects
14 did you work on when he was not there to fill your time
15 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 Q I guess my question is this: Say you have to
Toll Free: 866.709.8777
Facsimile: 561.394.2621
0
Suite 600
ESQUIRE 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquireSOlUtiOns.COm
EFTA00182485
- Volume II October 20, 2009
139
• 2
take a half a day of work off, do you get paid for that?
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: 866.709.8777
Facsimile: 561.394.2621
• Suite 600
ESQUIRE, 4440 PGA Boulevard
Palm Beach Gardens, FL 33410
www.esquiresolutions.com
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1 A At the end of the year.
2 Q At New Years?
3 A New Years.
4 Q 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 • Okay. So this would be in addition to your
15 salary of $42,000?
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
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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 Q 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 • 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 • Okay.
18 A It was not the same amount.
19 Q 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.
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1 Q And at that point in time you had really just
2 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 that correct?
15 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 2009, 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
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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 0 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.
9 Q You testified earlier about a who is the
10 housekeeper in New York, correct?
11 A Yes.
12 Q Now, when was the first time you met III 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 III I think had a surgery.
21 Q Okay. And you were there to cover fur her
22 while she had surgery?
23 A Yes.
24 Q And how long were you there?
25 A I cannot remember, but after her surgery, then
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we left to Palm Beach.
2 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
8 surgery, you were the housekeeper then in New York while
9 she was out, correct?
10 A Yes, sir.
11 Q 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 see. Then she went and had her surgery.
17 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.
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• 2
BY MR. MERMELSTEIN:
O Now, let's talk about the other times that you
3 went, you traveled to New York. When was the next time
4 afLeL Lecover.ed fLum lies sulyety Uiat you went to
5 New York?
6 A I think when she went to the Philippines.
7 O Okay. She went for like a vacation to go to
8 visit her family?
9 A No. I'm not really good. There was time I
10 went there because I think I sometimes interchange, but
11 T went there one time herAuse 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 Yes. Two separate times.
17 Q Both relating to Ms. Maxwell?
18 A No. The first one was -- first one to cover
19 up for III.
20 Q 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 Q I see. What's her name?
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1 A
2 Q And then there was another time where you went
3 to work for this party that she had, correct?
4 A Yes.
5 Q Okay. And the fourth time?
6 A When III went to the Philippines.
7 • 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, III
12 had her surgery, or was this a different time?
13 A Oh, what's this? Let me see. I cannot
14 really, what's this?
15 Q 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 • 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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• 2
while you've been employed by Mr. Epstein, traveled
anywhere else for work?
3 A No, sir.
4 Q Those trips to New York was the only time
5 you've traveled?
6 A Yes, sir.
Q You've never gone to New Mexico or to the
8 Virgin Islands for Mr. Epstein?
9 A No.
10 (Plaintiff's Exhibit No. 2 was marked for
11 identification.)
12 BY MR. MERMELSTEIN:
13 Q 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 Yes, 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.
41 Q Can you look through this and Lell me if any
22 of these, point out any of those that are in your
23 handwriting?
24 MR. REINHART: Take your time, look at each
25 one, and just tell him if you see any that you
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1 recognize your handwriting.
2 MR. CRITTON: You asked her to identify if she
3 sees anything in her writing?
4 MR. MERMELSTEIN: Yes.
5 THE WITNESS: (Shaking head.)
6 BY MR. MERMELSTEIN:
7 Q Okay. I understand your response is that you
B reviewed the various message slips included in Exhibit
9 No. 2 and none of them are your writing, correct?
10 A Yes, correct.
11 • But you do recall writing messages on this
12 type of pad for Mr. Epstein, correct?
13 A Correct.
14 MR. CRITTON: Stuart, that was exhibit what at
15 Mr. Rodriguez's deposition?
16 MR. MERMELSTEIN: Exhibit 1 at Mr. Rodriguez's
17 deposition.
18 MR. CRITTON: Okay.
19 BY MR. MERMELSTEIN:
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
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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 MR. REINHART: 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 BY MR. MERMELSTEIN:
15 Q 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?
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1 A Yes.
2 Q 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. MERMELSTEIN:
12 Q You can answer.
13 A I cannot remember if they -- let me see.
14 remember . Because when Mr. Epstein arrives, most
15 of the time I'm already off.
16 • 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. MERMELSTEIN:
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
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BY MR. MERMELSTEIN:
2 Q Okay. There were females who would stay
3 overnight at the house, but you're not sure how they got
4 Lu Lite house; is that fait to say?
5 A Yes.
6 Q Did any of the females who came to the kitchen
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. MERMELSTEIN:
MR. CRITTON: Okay.
Yes.
Thank you.
16 BY MR. MERMELSTEIN:
17 Q 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 • Was she a girl who had come to give
24 Mr. Epstein a massage?
25 MR. CRITTON: Form.
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1 THE WITNESS: No.
2 BY MR. MERMELSTEIN:
3 Q 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 MR. MERMELSTEIN:
8 Q You don't know?
9 A I don't know.
10 Q And again, this girl you saw topless was the
11 only one you ever saw who was in any stage of undress in
12 the pool area at the house; is that fair?
13 A Yes.
14 Q You mentioned in your testimony earlier that
15 there was a back massager that was in Mr. Epstein's
16 bedroom, correct?
17 A In the massage room.
18 Q In the massage room. It was what, on the
19 floor, on the massage table, where did you find it?
20 A Sometimes on the, what's this, the table,
21 sometimes on the floor.
22 Q So this would be a regular thing, you would go
23 in the room to tidy up and you'd find this massager,
24 correct?
25 MR. CRITTON: Form.
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• 2
THE WITNESS:
BY MR. MERMELSTEIN:
Yes.
3 Q You referred to it as a back massager,
4 correct?
5 A Yes.
6 Q And did you do anything to this, did you put
7 strike that.
8 Did you put away this massager?
9 A I return it to the drawer.
10 Q Was that a drawer in the armoire?
11 A No. In the bathroom.
12 Q In the bathroom cabinet?
13 A Yes.
• 14
15
Q
A
Were there other items in the drawer?
Lotions.
16 Q So those wore maccagc itemo
17 MR. CRITTON: Form.
18 BY MR. MERMELSTEIN:
19 Q -- that were in the drawer?
20 MR. CRITTON: Sorry. Form.
21 THE WITNESS: From Bodyworks, aroma massage
22 therapy.
23 BY MR. MERMELSTEIN:
24 Q So there was Bodyworks lotions and this back
25 massager; is that correct, in the drawer?
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1 A Yes.
2 • Anything else in the drawer?
3 A That's all. And I put some, like, hand
4 towels.
5 Q In the drawer?
6 A Yeah. On the side.
7 Q Was there any -- was there just one drawer
8 that was used for these massage materials, or was there
9 more than one drawer?
10 A There is only one drawer.
11 Q Would you do anything to this massager before
12 ycu put it in the drawer?
13 A No. I just return it there.
14 • Did you ever clean it?
15 A There was one time I clean it.
16 Q One time you clean it. About how many times
17 did this happen that you picked up the massager and put
18 it in the drawer; did it happen many times?
19 A Yes.
20 Q So on this one occasion why did you clean it?
21 A Because I thought it was, like, dirty, so I
22 clean it.
23 • Explain to me how it was dirty.
24 A There is -- the color is -- like you know
25 when -- like there is stains or something, you know,
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• 2
when something is not clean.
cleanliness, so I...
So I very particular about
3 O Did you believe that there was a sexual fluid
4 on it and that's why you cleaned it?
5 A No.
6 MR. CRITTON: Form.
7 THE WITNESS: No.
8 BY MR. MERMELSTEIN:
9 Q Mr. Rodriguez testified that you disliked the
10 task of putting away the massage items because you had
11 to clean them of sexual fluids and that was unpleasant.
12 Is that not true?
13 MR. CRITTON: Form.
• 14
15
THE WITNESS:
BY MR. MERMELSTEIN:
Not true.
16 Q So Mr. Rodriguez would be lying about that,
17 correct?
18 A Yes.
19 Q The way I asked that question was sexual
20 fluids, and that may be an ambiguous term. What if I
21 used the term "body fluids," does that change your
22 answer at all?
23 A No.
24 Q It's the same, you never cleaned body fluids
25 off of a massager, correct?
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I A No.
MR. CRITTON: Wait. You said -- when he said
3 correct, you said no. Does that mean he's not
4 correct?
5 MR. REINHART: Did you ever clean body fluids
6 off of a massager?
7 THE WITNESS: I don't know if it's fluid,
8 so.. .
9 BY MR. MERMELSTEIN:
10 Q Did you ever clean body fluid off of any
11 massager?
12 MR. CRITTON: Form.
13 THE WITNESS: No.
14 MR. MERMELSTEIN: I pass the torch.
15 CROSS (
16 BY MR. HILL:
17 Q I'm the mysterious voice that was on the phone
18 before, and now you get the privilege of seeing me in
19 person. I'm teasing, the privilege is mine. I won't be
20 very long with you, I promi
DataSet-10
Unknown
7 pages
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA-JOHNSON
JANE DOE NO. 2,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR
PROTECTIVE ORDER AND TO_QUASH SUBPOENA FOR
DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE
CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED
MEMORANDUM OF LAW IN SUPPORT
Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his
Response to Plaintiff's Motion for Protective Order and to Quash Subpoena for Deposition of
Jane Doe no.3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated
Memorandum of Law (hereinafter, the Motion"), with incorporated memorandum of law. In
support, Defendant states:
I. RESPONSE WITH INCORPORATED MEMORANDUM OF LAW AS TO
DEPOSITION OF JANE DOE. NO.3 AND MOTION TO CONSOLIDATE
a. The Depositions
Plaintiff, Jane Doe No. 2, filed this federal lawsuit against Defendant, Jeffrey Epstein. In
another separate matter, a Plaintiff, Jane Doe, No. 3., filed her own separate lawsuit against
Defendant, Jeffrey Epstein. Plaintiff's counsel represents all Jane Does in cases Jane Doe Nos. 2
through 7 before this court.
EFTA00729278
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Plaintiff, Jane Doe. No. 3, served answers to interrogatories wherein she lists certain
witness that may have knowledge regarding the facts and allegations alleged in her complaint
including, but not limited to, Jane Doe No. 2. See Exhibit "A", Answer to Interrogatories, No.
5, in redacted form. In particular, the response to interrogatory number 5 states that Jane Doe
numbers 2 and 3 accompanied each other to Defendant's estate. Plaintiff admits this much in her
Motion. Defendant seeks to take the deposition of Jane Doe. No. 3 as a witness in the instant
matter and as a party in Plaintiff her own case, which she is an unidentified Plaintiff traveling
under Jane Doe. No. 3.
In an attempt to resolve this matter by letter correspondence, Defendant agreed and
offered only to take the deposition of Jane Doe. No. 3 as a witness in all Jane Doe 2-7 cases only
one time and separately one time as a Party Plaintiff in the matter Jane Doe No. 3 filed against
Jeffrey Epstein. While this is a reasonable compromise in that Defendant has agreed not to take
her deposition three (3) times as Plaintiff suspected, Plaintiff's counsel refused to agree. Plaintiff
cannot file a lawsuit and then expect this court to protect her from being deposed as a party for
the time period proscribed under the federal rules while at the same time asking this court to
limit or prevent her deposition testimony as a witness in the instant matter or other Jane Doe
matters where she has been identified as a witness.
It is well settled that a Defendant may take the deposition of a party and/or a witness
before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp.,
43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2 and 3 commenced separate civil actions upon
the filing of same against Jeffrey Epstein. Therefore, Defendant is entitled to depose Jane Doe
Nos. 2 and 3 in their own cases at least one time for the proscribed time periods and then as a
witness in the instant matter or any matter they have knowledge of as reflected in the
EFTA00729279
Page 3
interrogatory responses. Therefore, Defendant has a right to depose each party-plaintiff
separately and then as a witness at least once. Deposing Jane Doe No. 3 as a witness in the
instant matter is necessary as that deposition will be tailored toward facts known by Jane Doe.
No. 3 as those facts pertain to Jane Doe. No. 2's claims in her complaint as opposed to the facts
alleged by Jane Doe. No. 3 in her individual action.
Plaintiff's attorneys claim that sitting for more than one deposition will be traumatizing
does not modify the rules and/or the law with regard to the right to take party and witness
depositions. Plaintiff offers no expert medical or psychological support, by an affidavit of an
expert or the Plaintiff herself, to support her position. In almost all instances, none of the
Plaintiff's sought or received any psychological counseling until the concept of a lawsuit and
money was introduced. A party may, by oral questions take the deposition of any person,
without leave of court. Rule 30, Fed.R. Civ.,P. Conducting these depositions separately will
allow for the proper preparation as to each deponent's knowledge as that knowledge pertains to
the specific case at hand (i.e., whether the deponent is a witness and/or a party plaintiff). Again,
Defendant is willing to conduct one (1) deposition in connection with each matter before this
court wherein a Party to one matter is listed as a "witness" in another. That is, if Jane Doe No. 3
has knowledge as a witness to one or more matters, one "witness" deposition will be held.
However, Defendant is also permitted to separately take a party-plaintiff deposition of any party-
plaintiff that happens to be a witness of and/or have knowledge of any other party-plaintiff's
deposition. As such, only two depositions will occur.
There is no legal basis supporting Plaintiff's proposition that Defendant not be allowed to
take the deposition of Jane Doe. No. 3 as a witness in the instant matter and as a party-plaintiff in
Jane Doe. No.3's separately filed action. In fact, Plaintiff's theory flies in the face of the Federal
EFTA00729280
Page 4
Rules. Despite Plaintiff's contention, Defendant is not attempting to depose or call a witness
for a second deposition without leave of court. Quite the opposite, Plaintiff is simply doing what
the rules allow for — the taking of a deposition of a party and a witness.
b. Consolidation For Discovery Is Not Practical
Next, if this case is consolidated for discovery purposes and depositions are limited only
to one (1) deposition for a party plaintiff and for a witness that happens to be a party plaintiff in
another matter, then confusion will result and motions in limine will undoubtedly be filed at a
later date preventing the use of certain testimony at particular hearings and ultimately at trial.
Further, since there remain separate party-plaintiffs, admissions or answers to discovery by one
party, arguably, cannot be used by the Defendant in a consolidated discovery matter against
another party-plaintiff. As such, consolidation in the instant matter is not warranted in that not
all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911
F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of
convenience of some witnesses, actions did not share all witnesses and parties were not
identical); Borough of Olyphant v. PPL Corporation et al. 153 Fed.Appx. 80, 2005 WL 2673489
(C.A.3 (P.A.)); Ford Motor Credit Company v. Chiorazzo 529 F.Supp.2d 535 (D. N.J. 2008).
Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery
is not mandatory but that decision remains within the sound discretion of the court. In this
instance, various Jane Does seek to consolidate the cases for discovery purposes. Very clearly,
the facts and circumstances, as pled and as is reflected in answers to interrogatories, are different
for each individual, i.e. the dates, the ages, the events, their experiences, witnesses, medical
and/or psychological treatment, etc. Each of the Plaintiffs alleged incident history and post
EFTA00729281
Page 5
incident history and background is unique to those individuals. While Jane Doe Plaintiffs may
wish to serve a "standard" set of interrogatories, request for production, or any other type of
discovery, the Defendant's discovery to the individual Plaintiffs, and certainly their responses, is
unique to that individual. There will be multiple instances where the discovery is applicable only
to a specific Jane Doe and not all, such as, physicians, psychologists, parents, siblings, friends,
employers, teachers, individuals with whom the Plaintiff has had relationships — many of these
depositions will go to damage related issues wherein the Plaintiffs seek millions of dollars in the
form of compensation.
There are some instances where the deposition of a particular individual may be
applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
Plaintiff's counsel that that particular deposition be used in all cases. However, in a vast
majority of the instances where discovery, deposition and/or paper discovery is being utilized,
including subpoena which will be sent to many different sources for each of the six Jane Does,
consolidation serves no purpose.
Even if this court consolidated the matters requested by Plaintiff, the undersigned would
still be entitled to additional time to depose any party-plaintiff that is also listed or who has
knowledge of any aspect of any other party-plaintiff's claim against Jeffrey Epstein. In addition,
this Court has before it each of the cases filed by certain Plaintiffs against Jeffrey Epstein.
Therefore, there is no chance of "conflicting results" as to rulings made by the same court and
the same judge. As such, no true need exists for consolidation. Under Fed.R.Civ.Pro. 42,
consolidation for discovery is not required, but remains within the sound discretion of the court.
EFTA00729282
Page 6
IL Conclusion
In sum, if Jane Doe No. 3 has knowledge as a witness to one or more matters, one
"witness" deposition will be held as to her witness knowledge. However, Defendant is also
permitted to separately take Jane Doe. No. 3's deposition as a party-plaintiff.
WHEREFORE, Defendant requests that this Court deny the Motion, enter an order
allowing for the relief requested herein and for such other relief as this court deems just and
proper.
Robert D. Critton, Jr.
Attorney for Defendant Epstein
Certificate of Service
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
day on all counsel of record identified on the following Service List in the manner specified by
CWECF on this day of April, 2009:
Stuart S. Mermelstein, Esq. Jack Alan Goldberger
Adam D. Horowitz, Esq. Atterbury Goldberger & Weiss, P.A.
Mermelstein & Horowitz, P.A. 250 Australian Avenue South
18205 Biscayne Boulevard Suite 1400
Suite 2218 West Palm Beach, FL 33401-5012
Miami, FL 33160
Co-Counselfor Defendant Jef•ey Epstein
ounsel or Plamtill lane Doe
EFTA00729283
Page 7
Respectfully submitted,
By:
ROBERT D. CRITTON, JR., ESQ.
MICHAEL J. PIKE, ESQ.
Florida Bar #617296
BURMAN. CRITTON. LUTTIER & COLEMAN
5611515-3148 Fax
(Co-Counselfor Defendant Jeffrey Epstein)
EFTA00729284
DataSet-10
Unknown
1 pages
From: lia >
To: (CID) (FBI)" aME>
Subject: JE
Date: Wed, 24 Jun 2020 14:04:57 +0000
Importance: Normal
She lied during a 2016 civil deposition where she was asked specific questions about her involvement with
Epstein.
SSA -
FBI New York
On Jun 24, 2020 10:02 AM, ' (CID) (FBI)" c wrote:
EFTA00147932
DataSet-10
Unknown
1 pages
To: jeeyacation@gmail.com[jeeyacation@gmail.com]
From: Lesley Groff
Sent: Wed 9/2/2009 2:42:58 PM
Subject: Reminder
According to "depositios currently ashceduled as of aug 26, 2009" CMA has a
deposition scheduled for 9-3-09 at 9 am. (By video)
EFTA_R1_01508616
EFTA02436223
DataSet-10
Unknown
1 pages
From: David Mitchell <
Sent: Thursday, October 11, 2018 7:27 PM
To:
Subject: Re:
I will return his call , in deposition
DAVID MITCHELL
Mitchell Holdings LLC
745 Fifth Avenue
New York NY 10151
USA
1212-486-4444
<1=>
On Oct 11, 2018, at 12:18 PM, J wrote:
you said you would know the price of the sculptrues today&=t; nu?
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
EFTA_R1_01826364
EFTA02620468
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Unknown
1 pages
From: Lesley Groff
To: "Jeffrey E." `t ille
Subject: Chester Brewer re Scarola
Date: Wed, 28 Jan 2015 16:38:38 +0000
Please call Chester Brewer..he needs to speak to you re Scarola... Scarola wants to take his
deposition and Chester wants to stop this...Darren suggested Chester speak to you directly
about this.
EFTA00353688
DataSet-10
Unknown
1 pages
To: Jeffrey epstein[jeevacation©gmail.com]
From: Matthew I. Menchel
Sent: Tue 2/15/2011 2:14:29 AM
Subject: RE:
We are on. My apologies for the late reply. I was in an all day deposition and
then had to rush to have dinner with my bride. As it happens, I have to be in
the Fort Lauderdale area tomorrow afternoon so we can meet up there or I'm happy
to meet further north if you prefer that.
Matthew I. Menchel
KOBRE & KIM LLP
www.kobrekim.com
New York I London Hong Kong I Washington DC I Miami
Original Message
From: jeffrey epstein (mailto:jeevacation@gmail.com)
Sent: Monday, February 14, 2011 7:10 PM
To: Matthew I. Menchel
Subject:
Are we still on ?
Sorry for all the typos .Sent from my iPhone
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
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IRS Circular 230 disclosure: Any tax advice contained in this communication
(including any attachments or enclosures) was not intended or written to be used,
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has been affixed pursuant to U.S. Treasury regulations governing tax
practitioners.)
EFTA_R1_00216186
EFTA01835821