IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SC .41 T1RTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiff. ### PLAINTIFF/COUNTER-DEFEND Y EPSTEIN'S MOTION TO COMPEL AYTQI CORDING Cos Plaintiff/Counter-Defendant, Jeffrey ("Epstein"), moves to compel J. Edu'" , wards") to produce the April 7, 2011, audio recording of the telephone interview l inia M. and in support thereof, states: Defendant/Counter-Plaintiff ### Introduction Epstein requests to compel to produce the audio recording of the telephonic intervi of g ta taken April 7, 2011. Pursuant to the "best evidence" rule, the mid' must be produced. Epstein appropriately requested the audio recording ailed to timely produce it. ### Epstein's 2011 Discovery Request for Production of Audio Recording - 1. On May 17, 2011, M, in support of his Motion for Leave to Amend to Assert a Punitive Damages claim, filed the transcript of an April 7, 2011, telephonic statement of November 29 and December 5 and 7, 2017 this matter will be tried. In additio would be calling clients (E.W., L.M. or Jane Doerudestify live at trial. **3. Undersigned counsel appeared c on November I, 2017. At the, the Court made rulings that impacted how hose hearings, counsel stated that he eged victim of Epstein but not one of three** 4. As a esult, on January 17, 2018, Epstein's counsel's office made a request to Edward's co ce for the audio tape of April 7, 2011, telephonic statement. D counsel's office has ignored this request. 1. Furthermore, Second Amended Exhibit List, No. 106 identifies "Statements, deposition transcripts, videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto." Exhibit E, No. 106. While EM April 7, 2011, telephonic statement was used in this case, has not produced the audio portion. a copy of which is attached as Exhibit A. The transcript indicates that ■ **was being recorded. Id.** **2. The audio recording should have been produced in response to Epstein's December 9, 2011, Request for Production. In that request, Epstein asked "Witness statements you intend to use in this case." Exhibit B, Request No. 7. were defined to include "recording of sound." Id., Instruction No. 7. Alth months before the Request was served filed the transcript of In d statement on which he relied and in fact used in this case, =t ) "None" to the request. Exhibit C, Request No. 7. to produce, "Documents" t a few ' telephonic** ### **This Court's Recent November/Dec Prompted a Second Request for ' e e Rulings Recording** 6. Epstein's counsel was not present during April 7, 2011, telephonic statement. Furthermore, from the face of the written transcript, it cannot be determined whether the statement was given under oath, nor does the transcript identify who transcribed it. # Florida Evidence Code Requires Production by of the Best Evidence Section 90.502, Florida Statutes, of the Florida Evidence Code provides that "an original writing, recording or photograph is required to prove the contents of the writ Sing, or 4) (holding that a tape recording, despite an available transcript and no dispute 's audibility, was still the best evidence of the tape's contents). photograph." See also v. State, 632 So. 2d 1099, 1100 (Fla. 10 Because the audio recording is the best evidence, ds' possession and properly requested by Epstein, should be compel! 1140, v. State, 189 So. 2d 890 (Fla. 1' DCA 19 S ordings" of written transcripts of tape recordings were the best evidence). the audio recording. See Duggan Accordingly, Epstein resp ests that the Court compel to produce the audio portion o 7, 2011, telephonic statement. **CERTIFICATE OF SERVICE** I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on February 15, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). LINK & ROCKENBACH, PA\ 1555 Palm Beach Lakes Boulevard, Suite 301\ West Palm Beach, Florida 33401\ (561) 727-3600; (561) 727-3601 [fax] By: /s/ Scott J. Link\ Scott J. Link (FBN 602991)\ Kara Berard Rockenbach (FBN 44903)\ Angela M. Many (FBN 26680)\ Primary: Scott@linkrocklaw.com\ Primary: Kara@linkrocklaw.com\ Primary: Angela@linkrocklaw.com\ Secondary: Tina@linkrocklaw.com\ Secondary: Troy@linkrocklaw.com\ Secondary: Tanya@linkrocklaw.com\ Secondary: Eservice@linkrocklaw.com *Trial Counsel for Plaintiff/Counter-Defendant\ Jeffrey Epstein* **SERVICE LIST** | Jack Scarola
Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
mep@searcylaw.com
jsx@searcylaw.com
scarolateam@searcylaw.com
Co-Counsel for Defendant/Counter-Plaintiff
[REDACTED] J. [REDACTED] | Nichole J. Segal
Burlington & Rockenbach, P.A.
Courthouse Commons, Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
njs@FLAppellateLaw.com
kbt@FLAppellateLaw.com
Co-Counsel for Defendant/Counter-Plaintiff
[REDACTED] J. [REDACTED] | | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | J. Pottinger LLC 425 N. Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301-3268 brad@eplIc.com staftefile®pathtojustice.com Co-Counsel or D endant/Counter-Plaintiff J. Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 marc@nuriklaw.com Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 jgoldbergerOagwpa.com smahonev®aewpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein esA Co # EXHIBIT A NOT A CERTIFIED COPY IN THE CIRCUIT COURT OF THE\ FIFTEENTH JUDICIAL CIRCUIT, IN AND\ FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually,\ [REDACTED] J. [REDACTED], individually,\ and L.M., individually, Defendants. \_\_\_\_\_ **NOTICE OF FILING** COMES NOW the Defendant/CounterClaimant, [REDACTED] [REDACTED], by and through his undersigned counsel, and hereby files the attached transcript of the telephone interview of [REDACTED] to supplement the proffer made in support of Counter-Claimant's Motion for Leave to Amend to Assert Punitive Damages. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all Counsel on the attached list on this 17 day of May 2011. ![](<>)\_\_\_\_\_\ Jack Scarola\ Florida Bar No.: 169440\ Searcy Denney Scarola Barnhart & Shipley, P.A.\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach, Florida 33409\ Phone: (561) 686-6300\ Fax: (561) 383-9451\ Attorney for Defendant/CounterClaimant\ [REDACTED] FILED 2011 MAY 17 PM 4:00 NOTICE OF FILED [REDACTED] adv. Epstein\ Case No.: 502009CA040800XXXXMBAG\ Notice of Filing Supplement COUNSEL LIST Jack A. Goldberger, Esquire\ jgoldberger@agwpa.com;\ smahoney@agwpa.com\ Atterbury, Goldberger & Weiss, P.A.\ 250 Australian Avenue South, Suite 1400\ West Palm Beach, FL 33401\ Phone: (561)-659-8300\ Fax: (561)-835-8691\ Attorneys for Jeffrey Epstein [REDACTED] Weinberg, Esquire\ Weinberg, P.C.\ 20 Park Plaza, Suite 1000\ Suffolk, [REDACTED] 02116\ Attorneys for Jeffrey Epstein [REDACTED], Jaffe, Weissing, [REDACTED], Fistos &\ Lehrman, PL\ 425 N. Andrews Avenue, Suite 2\ Fort Lauderdale, FL 33301\ Phone: (954)-524-2820\ Fax: (954)-524-2822\ Attorneys for Jeffrey Epstein [REDACTED] L. Ackerman, Jr., Esquire\ [REDACTED]\ [REDACTED] Burnett, P.A.\ 901 [REDACTED] Point West\ 777 S Flagler Drive\ West Palm Beach, FL 33401-6170\ Phone: (561)-802-9044\ Fax: (561)-802-9976\ Attorneys for Jeffrey Epstein Marc S. Nurik\ marc@nuriklaw.com\ Law Offices of Marc S. Nurik\ One E Broward Blvd., Suite 700\ Fort Lauderdale, FL 33301\ Phone: (954)-745-5849\ Fax: (954)-745-3556\ Attorneys for Scott Rothstein RE: adv. Epstein 291874 ### PRIVILEGED PURSUANT TO FS 766.205(4) and/or WORK PRODUCT TELECON PARTICIPANTS: JACK BRAD DATE: April 07, 2011 JS: ack Scarola and Brad BE: H V: Hi Jack! Hi Brad! How you guys doing? JS: We're doing fine, thank you. I'm further, let me tell you, if I have want to be able to tape this co you? 1 of the trouble and before we go any ission, I have started a tape recorder and I atio from the very beginning. Is that alright with V: Sure, that's fine, Jack. 6\\pr kl JS: Ok, good, thank you. •appleciate that. Let me start off by introducing myself. I know that Brad has sp l\\ken,t2you about me but I am Brad's lawyer, and I assume that you can confirm I tha you -"&rhave never had any communication before. Is that right? V: That's c JS: have, however, gotten some information from Brad about conversations that ave had with him, and that will enable me, hopefully, to make this a little bit more fictent and take up a minimum amount of your time while still getting the information that we think is going to be helpful to us and to any jury that might ultimately have to hear these facts. So, let me begin by asking you first to tell us what your full name is. V: =. That's my maiden name. My married name JS: Could you spell your last name for us? That is your married last name: V: JS: Alright, thank you, and where are you living right now? V: I live in Australia. JS: And how long have you resided in Australia. JS: That is where you are right now, correct? We've reached you AuQtra ia for this phone conversation? V: This is my 19th year. V: That is correct, yes. JS: And what time is it in Australia right now? V: I think it's about 9:00 now. JS: Ok. That's 9am, correct? V: That's correct. JS: Alright. the re s conversation is because it is our understanding that you know a man by thciune ey Epstein, and I want to begin by asking you please to tell us about the circurrQykn s of your first meeting Mr. Epstein. V: Ok. I was intro to Mr. Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in -a-Lago and I was prompted by Ghislaine to come to Jeffrey's mansio tk alm each that a / P\\p fternoon after work to make some extra money and to learn abo assig She met me at the spa, and I was reading a book about anatomy, so I was already Injerested in massage therapy as it was and not having any of the education or 380ccivr anything behind me, I thought this was a great opportunity to work for her and go.:1So, I went to Jeffrey's mansion about 5 or 6 in the afternoon. My dad drove me re. My dad worked at Mar-a-Lago with me, and he met Ghislaine and she seemed like a nice, proper English lady, and she knows, I mean, you know, one time then \_once before I left to travel overseas, she just seemed really nice and like she would like to help me out. So my dad left, and I had no problem getting home that night, one of her drivers would take me back after my trial. So she led me upstairs, and into Jeffrey's bedroom, and past that is Jeffrey's massage room, which has got his steam room and a shower and a massage table, and there is actually an extra room that has, that nobody knows about it, it's kinds like a secret room and it's got a whole bunch of decorative pictures of pornographic literature and sex toys and I can ? what happened in there. JS: When you say that the room was hidden, [REDACTED] how was the room concealed? V: It wasn't like a door that you would normally go into, like some kind of special opening, you open that and then a little door, so it looks like it's a little closet so-to-speak, but when you walk in there, it's obviously a lot bigger than just a closet. It wasn't too big, but it was bigger, you know. It wasn't a gigantic room, it was just like a small room, which you know, it probably could fit some shoes in there, _ it had racks of shoes, boxes, some sweatshirts neatly folded, and the ceiling to the floor was covered in pornographic pictures of the girls that he had met. JS: When you say... V: So anyways, that was getting there, and I was introduced to Jeffrey, he was laying naked on top of the massage table, and obviously for one, I'm a 15 year old girl and seeing him on the table was weird but, also learning about anatomy and massage, I thought this would be part of it. So obviously, I thought it was part of the massage program, so I said ok, this is fine. And, he then instructed me on how to touch the body, Jeffrey's body, how to massage him, and for the first hour, it was actually a real massage, maybe not an hour, maybe like 40 minutes or something, but of something like that _ and that's when he turned over on the other side and to expose himself fully. So then Ghislaine told me that she wanted me to undress and began to take off my shirt and skirt, my [REDACTED] uniform from Mar-A-Lago, she also took off her shirt and got undressed, and so I was there with just my undies on, and she was completely bare, and made some kind of little flake about the underwear that I was wearing because it wasn't my normal sexy girl underwear and just like, I don't know, had red hearts on it or something like that; just your normal, you know, real cute underwear. Anyways, so during all of this I'm kind of like what's going on, how do I act, what do I say, I was so afraid of, not afraid or fearful for my life but _ unsure of how all this started and wanting to obtain a profession _ I was so afraid thinking about upsetting and disappointing them, I don't know, it's a weird situation by far and I was expected to _ Lick his nipples, instructed on how to do so by J.E. and give him oral sex while he wanted to fondle me, and then at the end, I was told by Ghislaine to get on-top and straddle Jeffrey sexually, and when we were done, we went and had a shower in the room and Jeffrey told me to wash him up and down, you know with a bar of soap and make sure he was all cleaned up. And then he took me downstairs and took me to two of the guards and told John to bring me home. John was the [REDACTED] at the time. JS: Let me interrupt you for just a moment there if I could, [REDACTED] You mentioned as you were recounting those details that you were 15 years old at the time. What is your date of birth? V: August 9th, 1983 JS: And can you tell us please, as best you're able to estimate it, what the date was when this first encounter occurred? V: I've got it written down. It's like - I'm not good with math — hold on — I thought I wrote it down but I didn't. I'm not too sure, I think it was 1998 off the top of my head and around June of 1998, I would say as I was turning 16 at the end of the summer. JS: Alright. You talked about the room where Jeffrey had the pornographic photographs. Did you actually see that room on the occasion of your first visit there? V: No, I got to see that room a few visits after but I was just trying to des that oom to you guys so you knew exactly what room I was talking about. JS: Another question for you, and I don't mean to be plying into al life, and if I ask you any questions at all that you're uncomfortable answ g, filen you just tell me that and we'll move on, because I appreciate your cooperation d the last I thing I want to do is impose upon that cooperation, but can you tell -p ere just generally what kind of sexual experience you had had prior to this confron ibq th Jeffrey? V: Yeah, sure. A close family friend has sexually e, and I was on the streets at 13 years old. I was picked up by a 67 year old ed Ron \_Eppinger\_ who did exactly what Jeffrey did with me abuse and viol thfulness & I was with him for 6 months. So, he was gone and then i dl a,us j6yfriend who was like my school friend from young days but we just kept coat id with each other and we were on and off constantly, and that was Tony Ir ua. and there was also another younger guy was near my age, Michael, I can't cm'nt er his last name, but yeah, there, I mean, there wasn't like a string of men Ptui g, but there was Ron, like I told you, and he was the first guy expecting me t oi' ,. ailed disgusting affairs. Jeffrey actually knew Ron, which was quite weir when 1/ tOld Jeffrey the story about Ron, and Jeffrey had actually met him, and yeah. v just another story, and yeah, there were a couple of men, but that gives yc u an idea. JS: Now whe &you vcribed the photographs in the room as pornographic, tell me just a little bi ut the photographs, if you would please? First, how many of them were there V: 00, and like I said, they covered the room from the ceiling, not the ceiling but e top of the edge of the wall to the bottom of the floor. I want to say at least a widred, even more, there could have been more in the boxes \_Some of them were A4\_ photographs, like the large size, some of naked women posing, you know, positions, sexy positions. Others were, you know, some girls had bikinis on, and it wasn't so pornographic, but it was all women, and it was all in a sexual nature. JS: Were there photographs where more than one person appeared? V: yeah, plenty of them. There were lots of naked photographs, I mean I was just trying to give you a visual range. There was anything from 5x6s to 4x8s to 8x4s. Some of them had frames, some of them were out of frames, but they were all, like I said, they were all women, they were all sexual in nature. JS: Was it your impression that there were a hundred photos of a hundred different people or were there multiple photos of the same woman or girl? V: There was definitely a lot of different girls. I mean it wasn't easy to sit the and say, you weren't finding 5 girls out of some photos, no. Were there a hundred di t ones? There could have been pictures of some girls, I really couldn't get elo ems ly to actually recognize faces or anything like that. But if you, you 'mow, t ge of them were all different, majority of them were different, yeah. JS: Did there ever come a point in time when you became awarKihat photograph of you had been added to the collection? V: Yes, there was. Ghislaine took several nude photo f me for Jeffrey. So, yeah, there were pictures of me and there were picture e Tasn't shy, that wasn't the only place in his house that he kept the photos. 11,\<1 splrotos all his house. If you looked in his den or on his desk or in on A teloal lile a giant table in his house, there were at least a hundred photos of g sh,qr es. Not all of them were naked, a lot of the ones that were all around his ho sey erc:fiot naked girls posing pornographically, some were pictures of celebrities a d politiZj he had 'mown or things like that or had pants on or whatever, but yeah, there wIt lot of mixed photographs in the outside ones. JS: Were there any photo s or young women that you knew or that you subsequently came to kn u saw in the house? V: there w e was pictures of II, pictures p'ctur pictures of me, pictures o t e regulars, but a lot of the girls, sometimes y could have like 7 girls a day, and he would only see those girls once if he of bo I don't know. These weren't my days. I heard he's gotten a lot sloppie e I le So, I don't know anyways, but when I knew him, there was just a, it see as such an influx of girls coming in and out, so did I recognize a lot of aybe, maybe not, but then they were all definitely beautiful, they were all age, some of them young, some of them older in their 20's, I mean it was just eh all beautiful. JS: You've told us about the first visit. Was there any discussion on the occasion of that first visit about your returning? V: Yes, they were very pleased with me and after the encounter was finished, the sexual encounter, he went and told me I did well and I have a lot of potential to become a massage therapist and if I'd like I could return tomorrow, you know, and do the same thing and get paid \$200/hr, so Jeffrey insisted that I come after work, and over the next few days, I guess the relationship grew into more, and within a couple of weeks, not even a couple of weeks, maybe a week, I had quit Mar-a-Lago and I was working for Jeffrey full time. JS: Ok, let's talk about your job at Mar-a-Lago, if we could. You said that your Dad was working there. What was his position at Mar-a-Lago? V: He was a maintenance supervisor I think is what it was called? He like tennis courts and air conditioners and things like that. aged the JS: What is your Dad's full name? V: Sky William= JS: And is he still living here in South Florida now? V: No, he's not, he's in California. JS: Ok. Is your Dad aware of what is currently'go(ng iyvsith regard to your having made public statements about your relationship wi V: Yes, he is well aware of it. I told my key n before all this stuff came out, because they were the first ones contacted yhmalists from Mail on Sunday. I know that they the Mail on Sunday printed I fia\*gone out and tried to, I mean I think one of the photos said that I was angry th effrey and the Prince walking together and that is why I came out and went lic th everything. Not true. I mean, I am angry about how they are still up to ek ys together and that they're still hanging out but I didn't contact the Mai on Sunday and I didn't bring it out. I figured that everyone was going to bring it outs ay and I better bring it out the right way. He's known everything from the start, and my family is very supportive with everything going on. JS: I'm kind o tgoing jump around a little bit and I apologize for that, but since the subject has cord t tell me first of all why you are providing this cooperation to us, and I am cert ery,dppreciative of it, but I want you to tell us why it is you've chosen to spend on the telephone and provide this information that you're now providing. V: t to help the bigger picture, you know, I think all of us can make a big difference in t of other people's lives and I think that this has gone on long enough and it's a big slap in my face that he can get away with hurting me so bad let alone so many other girls and laugh about it. I guess I talked to you guys out because I want to see the right thing happen, not just to him, but I want people in the world to understand this is not the way of life, you know, it's not acceptable to go out procure young girls and make them think that, this is the way you should be living and that's all. Yeah, I guess my reason for doing it is to help the bigger picture, you know, I'm a big believer in karma and I believe that good things will come back to you, so I guess that's why I'm doing this. JS: Just for the record, neither Brad, nor I, nor anyone representing that they have anything to do with us has made any promises to you. Is that correct? V: That is correct. I'll tell you, since this is our first conversation, that nobody has made me feel like I've been bribed or bought or had to say anything. I've told you anything that I know from my own self, not some things somebody told me. If anything, Brad's been extra careful not to tell me anything and let me do all the talking, so it's quite posite I think. JS: Alright. Let's get back then to the story of your relationship with effrx and we've talked about your first encounter with him and how it evolved fr r to your full time employment with Jeffrey, but what were you doing at M r-a-11 go efore you quit Mar-a-Lago? V: I was just a locker room attendant and sometimes r r ' bysitting for the rich and famous. So, I wasn't anything big. I worked in the That's why I was studying anatomy, because I was really really interested in a \_massage therapist\_, and at the locker room, I didn't do much. I mean I g tea for a living, I would, you know, make sure the toilet paper had a littletria in it after everybody went to the toilet, or wipe down the water from the bas' ow, it was a very easy peasy job. JS: Did you get that job through your D( V: Yes, my Dad got me the job. JS: Ok, and you were only 1 at the time, were they aware of how old you were at Mztr-a-Lago? V: Of course, deft e/y. We had to go through extensive, you know, we even had to get drug tested and t and so on and so forth. I mean, Mantas (?) is very strict on employme yeah verybody knew. JS: Ok. • th y ever any conversation with Ghislaine about how old you were before you we t,tak a to Jeffrey's mansion? : N he didn't ask me how old I was from the start, but when I did get to Jeffrey's pnsion, it was discussed how old I was. JS: With whom? V: During the entire hour of what I call the legitimate massage I was giving him, it was cat and mouse games getting information from me to find out who I am, am I a willing participant in these kind of things, and how would I react if they were about to take the next step. But they got information off of me, they got my age, they got my, a little bit of my history so they knew I was, you know, not very stable at home, and they knew that, you know, I was actually interested in making my life better by studying so what they were offering me was a chance to become a legitimate masseuse but it was getting trained. They would have people show me how to work the body and be called a massage therapist and get me books on it, and you know, keep me interested, and every time, you know, I was with Jeffrey, literally was about massages, I don't mean just going in and have sex with him. I mean massage, because it would always start out with massage and then it would lead into sometimes other things. JS: Alright, once this evolved. into full time employment, what did full t' e p yment mean? V: That was entirely having to travel with Jeffrey in every city. was in Palm Beach, I stayed at my apartment, and he would call me to his ouse once or twice a day sometimes, and that's, you know, do things with him. Sometim e'd go out shopping, sometimes we'd go out arid watch a movie. You know st le things like that, go to an expo or a fair, whatever it was. But when we other cities, I was at my apartment\_, I lived with him full time. What I mg time is even in the middle of the night, I could get a ring on my phone next t ell me to come in his room, you know, so it was literally full time. JS: When you say that when you were i /each you were living in your apartment, were you living on your own or ou Mng with members of your family at that time? V: No, after I y offered to get me an apartment in Palm Beach somewhere, Palm d it was a nice apartment. He furnished it for me, it was absolutely beauti ah, that's the only time I would spend time away from him really. JS: This apartment w Palm Beach Boulevard or out in the Village of Palm Beach? V: I so 3,5, °nit remember. I've been trying to rack my brain because the FBI was same thing and were trying to find it, but yeah, I'm Not sur . I didn't get to much time in it, I was only there about an entire week out of every month ly, but the majority of the time I "Edith Jeffrey anyways. It was somewhere in piiiim Beach. I don't know about Palm Beach drive. I don't even remember the Palm Beach drive anymore so I'm not too sure. JS: Ok, irjaa2 see if I can draw the distinction for you and maybe that will help you to help us? = Palm Beach is a village that is... V: No, no, no, I got Palm Beach, I just didn't know the Palm Beach Drive, like what street it's o o . Were you talking about a street? adv. Epstein Te ep one interview with Page 9 of 23 JS: Yes, I was talking about a street. Palm Drive is on the island of Palm Beach, and it's a street that is lined with larg palm trees, and I'm wondering if this was an apartment on the island or was this an apartment out west of town... V: No, it was actually in Palm Beach, not on the island. JS: Alright. V: I would be driven, it was closer to my family than it was closer to himAI)vite to be close enough to everybody else so that when I was in town, I cool nb, see them quickly. JS: Ok. So i we're not talking about Palm Boulevard. We talki g about the town of Palm west of town. Jeffrey got you an apartment out theti V: That's correct. JS: When he was in Palm Beach, you were generalki tying at the mansion, you were staying at the apartment that he got for you o el, town. V: That's correct. JS: Ok. V: I mean then there was tint nria say that every time I stayed at my apartment. There was times we'd fl 4 4om some city maybe too late at night to really want to go back home, so yoti ow, s like 12:00 at night or 1:00 in the morning. I was just staying in the yellow rcm r something like that; one of the guest rooms in Palm Beach. But majority of a time, I would definitely want to get back to my own apartment. JS: Alright. e general hours of your full time employment when ...? V: Ther et hours. It wasn't like logging, and you know, hitting the shift button, tl? e that. The way I would get paid would be, ok, if I was in Palm Beach, I ul ge \$200 an hour to massage Jeffrey or some of his friends and then go home. So it-w uld be like that. If I was traveling with him, it would be per massage, so I would be ejting paid per day. So I wouldn't be getting paid on an hourly rate. He wouldn't say ok, today you're going to work for me from 7:00 in the morning until 8:00 at night. It never like that. I was on call all the time. JS: When you were here in Palm Beach, were you actually getting paid only for the time spent massaging Jeffrey or were you getting paid from your arrival at his house until you left the house? JS: From the time the massage started. Ok. V: Sometimes we'd go there and I would wait for a while or talk with Ghislaine and Jeffrey about something or we'd meet somewhere and talk about something. A lot of times, I'd meet him upstairs in his room where he was ready for me. But then there was a lot of times where it didn't start tight away, so he couldn't really pay me from the e I got there sometimes unless it was just paid from the time I massaged him til e the massage was over. JS: Alright. Did your duties for Jeffrey ever include anything oth massages and sex in connection with the massages? Did he Ve responsibilities to perform? pr viding him you any other V: I was asked to do the same things that I did to Jeffrey t well. Those were my duties. He looked at it thj professional massage therapist, and maybe I need erotic massages on a few people. of his fellow colleagues as that I was going to be a entele, so he had me perform JS: Did that start here in Palm Beach County V: It did. The first one did. JS: Ok, and how long after you II one of his friends? ky did he first ask you to provide services for V: About 9 months, I thi months and a year, w . It wasn't a full year, it wasn't 6 months, but between 6 by I'm saying 9 months. JS: And when you p services to a friend of Jeffrey's, who paid you for those services? V: 14. I would get paid the next time I saw Jeffrey, so if I was invited to the otylito give a massage, I would give a massage, I would go home, and the next saw Jeffrey, he would pay me for what I did. So, it was paid always by him, up by him, so he always knew what to pay me. I did get tips and things like tha ,-if you call it that, you know, like a hundred dollar tip or something from a few of pm, you know, yeah. JS: Was them .. V: There was always payment from Jeffrey. JS: Was there ever any discussion with Jeffrey about what was expected to happen when you provided massage services to one of Jeffrey's friends? V: In a roundabout way, yes. In so many ways, Jeffrey really really had to train me, and that was why Ghislaine said that she and Jeffrey enjoyed me so much was because they never really had to speak much to me to tell me what they wanted me to do. You know, I wasn't waiting for you know, their directions. Jeffrey would tell me to go give an erotic massage to friends. He wouldn't give me much detail about it, but he would say to treat them like you treat me. JS: Did he refer to it as an erotic massage or are those your words? V: Erotic massage is my words. That's exactly what it was, but he would me to treat them how he wanted it, so I'd do what he wanted without havin o me words more. I mean, I complied with what he wanted because it wa at of a, I don't know, I don't know how to say it, it was just very mindboggl hqw let him have so much control or power over me basically. The massages would. routine to what Jeffrey wanted with my so called new clientele, and with theii wn words would ask me to provide them with sexual pleasure after the massage. JS: Did you ever report back to Jeffrey about what when you provided massages to his friends? V: Of course, of course, and I knew th gITds were reporting back to him as well because there were times where he ,Kild ins gate conversation by saying you know, so and so had a great time, you did dap!, you know so and so gave me a call and told J.E how it went ... JS: Did Jeffrey ever elicit de you? "Tell me what happened, describe in detail what went on?" V: No, but he wou d have augh, he had a laugh with me a few times about some of their different manne sr I guess you would say, like some of them, one guy had a foot fetish and t w4really weird and I mentioned it to Jeffrey, and we would have a laugh over ft. rdn't want to know details. He wasn't asking me "so tell me what did you guys Tri jiy." No, he just basically gave me a slap on the back and said, you know, d we had some kind of conversation about it. I can't recall any conversation of my head. I really don't know one. It's been that long. But yeah, we did out it briefly. IS: Can you give me an estimate as to the number of friends for whom Jeffrey provided and paid for your services? V: There was about, you know, I don't know, 8 guys possibly. JS: And are you able to name those people for me? adv. Epstein Te ep one interview with Page 12 of 23 V: No, not at this stage. I just, some of these people are really influential in power, and I don't want to start another shitstorm with a few of them. I'll tell you that there was some erotic massages given to, I'm just afraid to say it to you. JS: Ok, V: It's like geez, I don't know if I want to, I'm really scared of where this is go JS: Alright. I understand that, and as I told you from the beginning, if I as estion that you are uncomfortable answering, you just tell me that, and I ' I ve on, and I understand that at least right now, you are uncomfortable answeri D certainly going to respect that. V: Thank you so much, Jack. JS: No, that's quite alright. I am very appreciate of the don't want you at any time to feel that we are takip so give me the information that you're comfo4b1 where you're uncomfortable, I will respect on you are providing, and I mr) dvantage of that cooperation, g me, and if we get to a point 11 move on from there. V: Ok. JS: I want to talk a little bit about the, g that you did with Jeffrey. About how long into your relationship with him6 id a irst start? V: Immediately. I started l.. fa lmn mmediately. Not internationally until I think about, Gosh, I can't remembf c even \*nk it was a year later that we started doing international travel. Maybe like 9 nkS,41 to a year again. Not too sure to be honest. JS: So that would ha n approximately the summer of 1999? Somewhere around there? V: Sgfqwhere around there. Somewhere around a year, somewhere around there, I .5111 it exactly. But like I said, we started doing domestic traveling ly, so my first destination with him was New York and Santa Fe and the California, I would take trips with him occasionally. Sometimes we would go Louis or New Orleans or Santa Cruz. We were traveling just about everywhere I JS: How did you travel? V: Well, we took Jeffrey's private jet, and unless I was being sent somewhere by myself for what we were just talking about before, then I would travel on a what do you call, a public jet, whatever it is... M adv. Epstein e interview with Page 13 of 23 V: Yes. Just a normal flight, an e-ticket. JS: Like the rest of us common folk. V: But when I was traveling with Jeffrey, the majority of the time would be on the black jet. JS: Now, when you say there would be times when you would travel by yourself se he was sending you somewhere, tell me about that. How did that come abo V: So, one of his colleagues would be at the Carribean or Santa Fe e e N w York, or wherever, and he would call me up on those days where I am n with him or in Palm Beach with him, and he would ask me to get on the nex Ian to so and so and go meet so and so, and that's when I would take e-tickets. His se to or special assistant, whatever, would organize it for me and give me the deJgiis d I would just walk up the line and they'd let me right through. JS: Can you give me any ideas as to how many t ppened that Jeffrey would send you off to meet some friend of his at some lo tde of Palm Beach? V: How many times it happened? I'm not ure robably about 10-15 times. JS: Ok. And on those occasions, ho ~mtlelytime would you spend with one of Jeffrey's friends when you were sent to that you would have to travel to? V: Only a couple of days. O that's it. JS: And how were you pa14 or hose trips? V: I would be paid t upon my arrival back with Jeffrey. So, whenever I was back with Jeffrey, he uld unt up how many days I've had, sometimes give me even more than what I ed, not deserved, but what I earned and give me a little extra. JS: W i a daily rate for those trips or was that per massage also? V: -Per-,Massage. With Jeffrey, I would be honest. I wouldn't tell him I did 15 massages if I i/cIn't. He knew he could trust me. He could always come back to the other person that he sent me to give massages and ask them as well, so you know, it was always by per massage. JS: Alright. When we've been talking about massages, tell me exactly what it is we're talking about when we speak about massages. V: Same thing I would do to Jeffrey. Again, it would start out as a massage, which would start with them being naked, and me giving him a legitimate massage to begin with, so I'd start with his feet, go up to his calves, up his legs, buttocks, back, his neck, his head, his arms, yada yada, and then it would be time to flip over, and some of the men would want me to continue on massaging the front side of them and they would instigate me to begin having sex with them or foreplay, whatever you want to call it. JS: So routinely, these massages involved sexual activity. Is that accurate? V: That is accurate. JS: Ok. Let's talk about the travel that you were involved in when you private plane. Generally speaking, who were the passengers o traveled. on Jeffrey's e when you V: Well, Larry was the pilot, and then there was a short, small s id\_ ty, I don't know his name, but he was a co-pilot, and then he changed and was another guy brought in Generally speaking, there was always Jeffr times Ghislaine, sometimes sometimes a whole bunch of other girls toes famous people, sometimes some politicians or yeah, just about anybody cptiki if his plane. There was never no any set routine who would come and who alch It was an influx of people on Jeffrey's airplane. JS: I want to deal with these things that you have, so I'm going to with Jeffrey on his plane whe there was any sexual activi implicate any of these f names of the people arc.that ely~)I(order to respect some of the reservations ho the people were that you remember flying re personally present without regard to whether un-ed on the plane or not. So I'm not asking you to ople in improper conduct, but just tell me what the remember that you consider to be famous people. V: Ok, there was aomi C pbell, Heidi Klum, there was Bill Clinton. There was Al (7) Gore, there was e bunch of models, I wouldn't really honestly be able to give their names. T ere w att Groning the producer of the simpons cartoon, Jack CCousteau's grandd ter a lot of interior designers, architects, politicians. I am just trying to think of as a y n hes as possible for you. Off the top of my head, that's as good as I can get JS: right, that's fine. And again, I am not implying by my questions, nor do I want qur answers to be interpreted as your suggesting that any of those people that you have just identified were engaged in any improper activities on any particular flight, but I want to talk to you now about what went on on occasion on the airplane. Ok? V: Ok. It was a lot of the same thing that went down on the ground. A lot of times, it would be just be me and Jeffre or me and Jeffrey and Ghislaine, or me and Jeffrey and some other girl, sometimes . There would be sexual conduct, there would be foreplay, there was a bed in there, so we could basically reenact exactly what was happening in the house. It would start off with massaging or we would start off with foreplay, sometimes it would lead to, you know, orgies. JS: Were there occasions when you were in Jeffrey's company, whether on the ground or in the air, where there were other girls present whom you knew to be under age 18? V: Yes. There was a constant influx of girls coming in and going out. And we we all very young. On occasion, there was some older girls, and I don't mean older as ' ik in their 30s or anything, I mean like 28, 29, something like that, just very rarely nty of the girls that Jeffrey actually met or had on his plane or in his house were er age. JS: Do you know how it is that Jeffrey established with any of these girls? V: Yes, I do. He would send me personally or with other girls to t:tr shops, to \_pick up anywhere, I mean we were constantly on the look fQFQtler girls that might satisfy Jeffrey. JS: What instructions were you given about what to, l'a V: Young, pretty, you kno fun person ey couldn't be black. If they were any other descent other than =, they ha wally beautiful. That was just about it. JS: Who gave you those criteria? V: They both gave us the instru it wasn't just me, Jeffrey asked most girls to bring a friend and make extra ey would use us young girls So that way it probably looked a lot more safe at we were procuring to younger girls that were already doing it. That was the at Jeffrey had it. JS: Were you given truction at all on how to approach these girls? V: Yes. vT y and Ghislainc both taught me to, depending on the circumstances, depe 'the girl, you could offer them a job as a massage therapist or you could tell the y ave a really rich friend with, you know, great contacts in the acting world or world and he loves pretty girls, you should come back and meet him, make -some.tnoney, you know, we had a whole bunch of ways to be able to procure girls. IS: Can you give me any idea as to the total number of underage girls that you know engaged in sexual conduct with Jeffrey during the period of time you had your relationship with him? V: I would have no way of estimating that whatsoever. I mean, there could be a hundred, there could be more, honestly I'm not too sure how many girls, really. I wish I did know. I mean like I said there were so many over the course of 4 years with Jeffrey. Let me see if we can try to narrow it down a little bit. Is there any doubt in your mind that it was more than 10? JS: V: Yes, there was definitely more than 10. JS: Ok, what I want you to do is to give me the highest number that you are comfortable in saying there were definitely more than X number of underage girls that I kn Jeffrey Epstein engaged in sex with while I had a relationship with him. How woul fill in that blank? Definitely more than how many? V: I'd say definitely more than a hundred. IS: Alright. Did Jeffrey ever help to pick out your clothes? V: II yes. I mean he wasn't out to dress me like a porn nything. He would always dress me very classy, but we'd just go shopping all th ther. JS: Did he ever express any style preferences ;I Besides dressing classy, I'm, you know, wanted you dressed? how he wanted you to dress? 'suggestion to you about how he V: He didn't, like I said, wasn't tryi that. It was nice, classy outfits I like that. He was buying me I was wearing miniskirts, tIbti my cleavage and everythi me in any prostitute way or anything like ng like Gucci, Dolce Gabbana, Chanel, things very nice clothing. It was provocative. I mean ort shorts and little shirts that showed my belly and ey were very expensive clothes. JS: Was there every any dc s44 role playing? V: Yes. There was) had bon ge ou schoolg; t of it. Jeffrey loved the latex outfits Ghislane had for us girls, he s, he had all different kinds of outfits, but his favorite was the JS: Tel out that V: you know, Ghislaine would take me to dress me up to surprise J.E or Jeffrey would it me to ge d up, that would include wearing a tiny little skirt with nothing underneath, a illic collared shirt that you would be wearing to school with a tie in it, tied up \_in a bow, my hair in pigtails, stockings on up to my knees, and I would go in there and act like a kid and we'd do role playing sexing. JS: Did Jeffrey ever brag to you about the age of any of the girls with whom he had relationships? V: Yes, he did. He did all the time. The worst one that I heard from his own mouth was this pretty 12 year old girls he had flown in for his birthday. It was a surprise birthday gift from one of his friends and they were from France. I did see them, I did meet them. Jeffrey bragged afterwards after he met them that they were 12 year olds and flown over from France because they're really poor over there, and their parents needed the money or whatever the case is and they were absolutely free to stay and flew out. Those were the worst ones. He was constantly bragging about girls' ages or where he got em from or their past and how terrible their past was and good he is making it for them JS: Where were the 12 year old girls flown to from France? Where did they e to? V: Palm Beach. JS: And were they flown in on Jeff's private plane or did they get t Cspirted? V: No. They were transported by somebody else. JS: Ok. Was the sexual activity that went on on t any of the crew was aware of what was goin conducted in such a way so that V: They were told to knock if they had to told, you know, to come out as all watching everything, no, but it down' well there's a whole bunch o constantly being massag reason? I mean, only the. o ;'if the crew had to come out. They were possible, so they weren't out there hanging out e an idiot to put two and two together to say sed teenagers on board with this old man who is and he wants me to keep the door shut for what that together, but yeah, they knew. JS: Did Mr. Epstein ever ou about people of power and influence owing him favors? V: He would laugh it, you know, I never really knew what to take serious from Jeffrey because h ass a funny character at times. You never knew if what he was saying was vu 'ot. cah, lots of people owed him favors from what he told me. Hc's got everyo t his pocket, and he would laugh about he helps people for the sole purpose they owe him something. That's why I believe he does so many favors in the JS: "When and how did you first become aware that Mr. Epstein was in trouble with the law? V: I was first informed by, I think someone from the FBI called me first and started to ask me questions, and I started to answer the questions but then fear took over, and I just said look, I don't know what's going on, I've got a young family that I don't want to risk, you know, please don't bother me about this again, and it was real short simple conversation, and within a week or 2, I had gotten a call from Jeffrey's attorney, and then a week later, Jeffrey himself. adv. Epstein Telep one interview with Page 18 of 23 JS: Ok, well let's back up before we get to those conversations and tell me approximately when it was that you were contacted by the person who you believe was with the FBI. V: Ok. It's hard for me to pinpoint, if I had to pinpoint it, it would be in 2007 sometime. JS: Alright. And you were living in Australia at that time, correct? V: Correct. JS: You were contacted by telephone? V: That's correct, by my cell phone. O le IS: Ok and do you have any idea how your name came up leading caat /contact. V: No idea. No idea whatsoever. When I did ask, I at some girls had revealed my name, I guess, and that's how everybody, the ft to contact me. JS: OK. V: But I don't know offhand or sorry, I ju;lllwwl cj into the wrong room. JS: Ok. V: Sorry go on. JS: Yes & I'll never tell id that. how long was it after that phone call from the FBI person u contacted by Mr. Epstein's lawyers. V: Like a week. It ck to back to each other. I remember being so scared after talking to the FBI thinIcin\*,what's happening, what's going on. It's been like 6 years, 7 years at that sta how did they find me & what do I have to do with this? So yeah, I do reme ber rvery well, and it was only about a week later I was called by his attorney. JS: it that contacted you, do you remember? V: Kant to say Bill Riley, but he might have been from the FBI. No, it was Bill Riley. Bill Riley. Not sure if that's his correct name, but that's what is coming to mind JS: What do you remember about that conversation? V: I remember a Mr. Goldberger as well, I remember, there might have been two of them. JS: Alright. V: I can't remember which one it was. I want to say Bill Riley is the good one. JS: Alright, so either Bill Riley or a Mr. Goldberger or both of them contacted you, and what do you remember about that? V: I don't know if it was the same guy who contacted me that week later who put me in touch with Jeffrey. I think he was on the phone and he put speakerphone on with Jeffrey. So he connected me with Jeffrey. I don't know if it was the same guy or different, but I definitely know that Bill Riley was the first guy to contact me. I'm pretty sure about that. JS: Ok. Tell me about that conversation. V: He asked me what I knew about what's going on with Jeffrey and apparently, there was an investigation being held about some of the girls who had come out and said that Jeffrey had sexual contact with them under the age of a minor and that he was discrediting lot of these girls and making them out to be drug addicts and prostitutes and what have you so they wouldn't be looked upon as worthy in the court's eyes so to speak. And you know, he told me in the first five minutes that, you know, if I stay quiet, that "I'll be looked after". And that was the exact way it was said. It wasn't like you know, I'm gonna pay you a zillion dollars or anything if you be quiet, but if I stay quiet, I would "looked after". And I remember saying I don't want any part to do with this. You know, this is not something I want to be a part of, I've got a young family. I wish the best for everybody in this, you know, take care kind of thing. A week later, I was called after the hearing by one of Jeffrey's lawyers. I can't tell you exactly which one it was but he had Jeffrey on the other line and he connected Jeffrey and I, and Jeffrey tried to make some simple conversation, "How are you? How have things been?" You know what I mean, catching up. JS: Do you know if the lawyer, did the lawyer stay on the line while Jeffrey was speaking to you? V: I'm pretty sure he did. That's why I think Jeffrey was on speaker phone because it sounded a lot different, and I was never taken off the line to begin with or connected to another line, so I was pretty sure Jeffrey was on speaker phone and the lawyer was making the call. After the simple conversation, it led to what was going on again and you know, Jeffrey couldn't believe it. You know, he thought he helped all these girls out. He didn't think he was wrong in any circumstance here at all. A lot of these girls were drug addicts and just after drug money. You know, he was really putting down these women or these girls I should say, not giving them the credit they deserved, and then he exactly repeated what the lawyer said the week before is that he would look after me if I stayed quiet, and if I need any help, you know, his lawyers would represent me and he would get legal help for me, whatever I need, he would do, and I told him exactly, I said, "Jeffrey, I'm the mother of two children at that stage. I'm away from everything there, I don't want to be a part of it. I'm not going to speak to anybody and I don't want to speak to anybody, I don't want to be involved." That was the last time I heard from him. And the next thing I knew, I was sent my victim's letter, my notification of being a victim through the US Attorney's Office and that's when I knew it was well out there enough not to have Jeffrey's lawyers come back on me and discredit me in the same way he had done to all the other girls. So, I called up Joseph Bird who was the recommended lawyers on my paperwork that they had given me and started going from there. JS: So you contact Mr. Joseph Bergs' office and then you were dealing with his office from that point forward. V: That's correct. JS: Tell me about the ending of your relationship with Jeffrey. That's, at what point in time did your full time employment end and how did that happen? V: Ok. So, it hadn't really ended. I walked away from it all. Jeffrey sent me to Thailand where I met my husband and escaped to Australia, never to return back to the states. About 6 months prior to that, he came up with a proposition that I thought was really disgustingly sick. And it really showed me for the first time in 4 years I had been with him that nothing was going to change and I was always just going to be used by him(?) which I did not like. He offered me a mansion and some of his money every month, I forget what he called it, a monthly income of what he made to bear one of his children. The proposition was that if anything ever happened between Jeffrey and I, that I would have to sign my child over to him basically and that the child would be his and Ghislaine's, and I would be looking after it as long as nothing happened between Jeffrey and I. So, I was kind of freaked out by all of that. I pushed Jeffrey more to please get me some more training, you know, and I was getting older and not of as much interest to Jeffrey anyways. I was 19 now, and he likes a female a lot younger. So he sent me to Thailand, in September 2002. I was first supposed to meet a girl there and bring her back with me, but I never met up with her. I proceeded get a short course in Thai massage so that was to shut me up about my training so I went there, and one of my friends from school invited me to watch a fight, like a muay thai fight, which is like a form kickboxing. So I went and watched it, and I saw this guy that was a really good fighter, and a girl's word, looked really hot, so I asked my friend who knew him to introduce me. We got introduced and fell in love immediately, 3 days later Rob proposed and 7 days later I was being married in a buddist temple. I called Jeffrey and told him I'm sorry, I'm never coming back. I've gotten married, I've fallen in love. I thought he'd wish the best for me but he was kind of rude and he just said "have a good life" and hung up the phone, and that was the last time I'd talked to him ever until all this started again. JS: Ok. [REDACTED] is there anything else that you would like to add to what you have told us up to this point in time? V: I'd like to know that this time around something's going to be done about it and that Jeffrey and a lot of his colleagues, no matter how rich they are, will know that there is law and that there is people that still believe in it. So that's it. Thank you guys for listening to me, hearing me out and helping me. It's kind of hard to get through. JS: Thank you very much. Yes, I'm sure it has been very difficult and I am very appreciative of the courage you have shown in doing what you have done, which really brings me to the last subject, and that is what was it that motivated you to go public with all of this? V: Sharon Richard contacted me. I like her, I do, I like her a lot. I know she's a journalist, and journalists are normally bloodsucking leeches, but I like her for that, but she is an honest bloodsucking leech. She told me a lot about what was still going on, and she showed me a picture of Jeffrey with a little girl who looks like she could have been 12 years old. I mean it was disgusting. I agreed to talk with her, I never agreed to do anything until she showed me some pictures, and at that stage, being a mother of 3 children and having a daughter who I would do anything for to protect, I would put my neck on the line to make sure she never has to go through what I had to go through, and knowing all of this, and knowing that he's still out there doing the same exact thing with no regrets, no remorse, no worry about what he's doing to, those girls, and all those girls feeling the same way that I did, so I, you know, I'm doing it because I believe in my heart of hearts it's the right thing to do. It's what I would want somebody to do for my daughter or my sister or my friend, and it saddens me to know that it's still going on right now. It's like the seashell story. I don't know if you're heard the story about the little kid who throws back a starfish, you know, the little brother tries to ask his sister, "why do you throw them in, they're all gonna die anyways, the little girl says "well, it's this one that I can help, and this one that I can help," and that's what I feel like I'm doing. I'm making a small dent in this big world we live in. JS: I certainly appreciate that courage, and I have heard that story, and you're absolutely right, that one person may not be able to make a difference for everyone, but one person can make a difference for someone, and hopefully, you are making a difference for someone, and we're gonna do the best we can to make sure you are making a difference for as many people as possible. V: Thanks Jack. JS: Just a few other follow up things I want to ask you and again, if any of these questions are questions that you're uncomfortable in responding to, then don't hesitate to tell me that. Do you have any recollection of Jeffrey Epstein's specifically telling you that "Bill Clinton owes me favors"? V: Yes. I do. It was a laugh though. He would laugh it off. You know, I remember asking Jeffrey what's Bill Clinton doing here kind of thing, and he laughed it off and said well he owes me a favor. He never told me what favors they were. I never knew. I didn't know if he was serious. It was just a joke. V: He told me a long time ago that everyone owes him favors. They're all in each other's pockets. JS: When you say you asked him why is Bill Clinton here, where was here? V: On the island. JS: When you were present with Jeffrey Epstein and Bill Clinton on the isl there? ho olse was ll V: Ghislaineand there was 2 young girls that I could id er really knew them well anyways. It was just 2 girls from New York. JS: And were all of you staying at Jeffrey's house on the is1aluding Bill Clinton? V: That's correct. He had about 4 or 5 different vill snstand separate from the main house, and we all stayed in the villas. JS: Were sexual orgies a regular occurrence o\\*Redaction has been made at the request of the witness. # EXHIBIT B NOT A CERTIFIED COPY ### IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ### CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. JEFFREY EPSTEIN, Plaintiff/Counter-Defendarit, v. SCOTT ROTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiffs. ### PLAINTIFF JEFFREY EPSTEIN'S SECONlik \`fir ST FOR PRODUCTION TO DEFENDANT/CO1UNTER-PL J. Plaintiff/Counter-Defendant Jeffrey ("Epstein") hereby requests that S' 1 Defendant/Counter-Plaintiff Bradley 3. Echi#1-s produce for inspection and copying those items requested in Epstein's Second Re4ueit roc Production within 30 days of service at the offices of Burnett P.A OM Point West, 777 South Flagler Drive, West Palm Beach, FL 33401. ### CERTIFICATE OF SERVICE I /ifargrit CERTIFY that a true and correct copy of the foregoing was served by e-mail and U.S. Mail on this 9th day of December, 2011 on: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Blvd., Suite 700, Fort Lauderdale, FL 33301. r NfrAiwn+Af J eph Ackerman, Jr. Florida Bar No. 235954 BURNETT, P.A. /r...4 901 Point West 777 South Flagler Drive West Palm Beach, Florida 33401tt" 7' Telephone: (561) 802-904 Facsimile: (561) 802799 6%;..)-• Attorneys for Plaintig-Jerney Epstein ### DEFINITIONS AND INSTRUCTIONS 1. The term "M," "you" or "your" means the party or parties to whom this Request for Production is addressed, i.e., Defendant/Counter-Plaintiff including, all persons acting or purporting to act on his behalf. j. 1. "Second Amended Counterclaim" means the Second unterclaim which you served on November 29, 2011 on the Plaintiff/Counter-Delendrutt Jeffrey Epstein in this action. • • 1. The term "witness" means any natural-tors\*/ individual, proprietorship, partnership, limited liability company, corporation, 41iate, subsidiary, association, • organization, joint venture, firm, other busine AtteSte, governmental body, group of natural persons or other entity. ( 1 %, \*.• 4. The terms "identify( "desbribe" or "provide" when used with reference to a ," natural person means: • A. the Anl name, current telephone number(s) and current business and home addresses (or, if tle•current telephone number and/or current business and home addresses are not known, ,the-laseknown telephone numbers and/or business and home addresses) of the person. 'Addresses shall include the street and post office box if known and the city, state, country and zip code; B. the full name and address of each employer, each corporation of which the person is an officer or director, and each limited liability company of which the person is a manager or a member, each partnership of which the person is a partner, and each other business in which the person is a principal; C. the person's current (o r, if the current is not known, the last 'known) • position, and the position or positions held by the person at the time of the actin which the response to a specific request relates; and D. such other information as is sufficient to provide full identification of the person; 5. The terms "identify," "describe" or "prov eti used with reference to any entity other than a natural person means: . \\ A. the full name of the entityXe'type of entity (e.g., corporation, limited liability company, partnership, etc.), thead1dres&f its principal place of business, its principal business activity, the jurisdiction under the aws of which it has been organized and the date of s such organization; B. each of the entity's officers, directors, shareholders, managers, members, partners or other pects' • -51. "any other available information concerning the existence or identity of the entity. 6: - The terms "identify," "describe" or "provide" when used with reference to a document means: A. the name or designation of the document; B. the name of the person(s) who participated in the creation of the document C. the date of the document; D. the person or entity to whom the document is addressed (ieltity) and those a". to whom any copies of the document were addressed or delivered; E. a brief description of the contents of the document; and. F. all signatories to the document. 7. "Doctunent" means any letter, correspondence, memorandum, report, calendar; diary, appoint/nen!' record (including business, financial and medical records), ledger, audi t ice, statement, schedule, recording of . sound or photographs, electronic file cwth: n disk, tape, drive or otherwise), printout, writing, drawing, sketch, notes (hitadviikten - or otherwise), map, blueprint, e-mail, data compilation; and written or recorded material of any kind and character. 1. "Referring.to," "reflecting," "evidencing" or "relating to" means in any way directly or indirectly, concerning, referring to, disclosing, describing, confirming, supporting, evidencing or seating. and "or" shall be construed in the disjunctive or conjunctive as necessary in order to bring within the scope of each request which might otherwise be construed to be outside its scope. 10. "Person" means any individual natural person, partnership, association, firm, limited liability company, corporation, organization, trust, governmental or public entity, and any of the officers, directors, shareholders, members, managers, partners, agents, employees, assigns or representatives of the same. I I. "Substantiate," "state" or "explain" means to produce documents or things that set forth the circumstances or bases for any belief, contention or position or giyettformation or direction in response to a request. ev A • -•t 12. If documents or things that are responsive to all or pari,of a specific request are not within your custody, possession or control, for each, state w,lien it was last in your custody, possession or control, and why it is no longer in your custodyr,pa ssion, or control and identify the person(s) that you know has or last had lieve has or last had custody, possession or control of such document or thi T s, • . 13. If you do not presently havetz.y.sr custody, possession or control, documents or things that are responsive to a reque0, inc e a statement to that effect, and at such time as any • "., responsive document or thing comes tnto your custody, possession or control, produce same within ten days of its location, and in any event, produce it no less than ten days prior to trial. 01. Ex where otherwise stated, the time period for the requests made herein is January 1, 2Qq the present. ## REQUESTS 1. Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered damage to your reputation as a result of tote filing of this action against you. 1. Each and every document that tends to support the claiN your Second 4. Amended Counterclaim that you have suffered damage as a result of iaterference in your professional relationships. 1. Each and every document that tends special damages, including loss of income; this r limited to, production of your federal income of income in 2011. to support anV claim you are making for l ecifically shall include, but not be or 2007, 2008, 2009, 2010, and records 1. Each and every doa&ten'l4hat tends to support the claim in your Second Amended Counterclaim that y4 hav luffered money damages resulting from the loss of the - - value of your time diverted from your professional responsibilities; this request specifically shall include, but not beetznited to, the production of all your time and billing records, calendars and diaries from 2Q0 ugh the date on which you respond to this request. h and every document, including, but not limited to, invoices and statements, that tendi to support the claim in your Second Amended Counterclaim that you have paid money or incurred obligations to pay money for your defense in this lawsuit. 6. Each and every document evidencing communications from others with respect to your reputation and standing in the legal community. - 7. Witness statements you intend to use in this case. - 8. All invoices and statements for legal services and costs incurred for the defense of this action against you. - 9. Each agreement or other writing memorializing the arrangemeneapursuant to which you are receiving legal services for the defense of this action, including4 riot limited to a retainer agreement with Searcy Denney Scarola Barnhart & Shipley, ZA. , - 10. Each and every document that tends to sholvethate your reputation has been damaged as a result of your relationship with Rothstein, Rosferifelcii& Adler. - • - • - 11. Each and every document reflecting gross collections received from your providing services as a lawyer for each of the y 007, 2008, 2009, 2010 and 2011. - 12. Invoices, statements of ac bother documents reflecting treatment for any physical or psychological injury yeti clack to have suffered as a result of this action being - ••%, brought against you. - 13. Each and every document reflecting the method used in calculating your loss of income, whether l awages or other remuneration, for the period you claim to have suffered damages. mit loss of future earning capacity as a direct result of the allegedly wrongful conduct. h and every document reflecting the method used in calculating your alleged - 15. Each and every document reflecting all lost business opportunities you claim to have suffered between 2009 and the present. 16. Each and every document reflecting the identity of the confidential source(s) listed on your Privilege Log dated February 23, 2011. 01. Each and every document reflecting the legal authority that justifies your refusal to disclose the identity of the person(s) identified as a confidential source in youe'Pervilege Log dated February 23, 2011. 01. All closing statements for all clients who you represented that brought claims • against the Plaintiff (and all other documents with respect tospcb clients), reflecting amounts paid to such clients or to you, your time, referring attooks apt amounts paid to the same, . advance costs, and payments to any other person or 01. All records of your contacts wi or other media outlets. 01. Any agreements and c4) .•. , • \`-c. 1 agreements for the sale of, developthent of,',)or any other transaction relating to, movie, book or other rights that you may or will benefit rom which are related to the claims you or your clients brought against the Plaintiff. ons relating to agreements or potential 01. All elocumentS supporting your alleged belief that law enforcement is still • investigating the Plaintiff/Counter-Defendant Jeffrey Epstein, including those reflecting cornmuratiffints with or information received from the government/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief. 01. All documents supporting your claim that "others still persist in prosecuting claims against Jeffrey Epstein." 01. All documents supporting your claims in Paragraphs 9 and 25 of the Second Amended Counterclaim in which you allege the sole purpose of filing civil claims was never to recover monetary damages, that PlaintiffCounter-Defendant Jeffrey Epstein knew he never suffered monetary damages, and that he knowingly asserted baseless and uns le claims, etc. # EXHIBIT C NOT A CERTIFIED COPY IN THE CIRCUIT COURT OF THE\ FIFTEENTH JUDICIAL CIRCUIT, IN AND\ FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually,\ [REDACTED] J. [REDACTED], individually, and\ L.M., individually, Defendant(s). FILED\ 12 JAN 9 PM 4:19\ SHARON R. BOGER, GLERK\ PALM BEACH COUNTY, FL\ CIRCUIT CIVIL A PLAINTIFF'S RESPONSE TO REQUEST TO PRODUCE Defendant/Counterplaintiff, [REDACTED] J. [REDACTED] by and through his undersigned attorney and pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby respond to Plaintiff/Counterdefendant, Jeffrey Epstein's, Request to Produce dated December 9, 2011 as follows: 1. 1. Objection. The identification of documents "that tend to support" a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege. 1. 2. Objection. The identification of documents "that tend to support" a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege. 1. 3. Objection. The identification of documents "that tend to support" a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege. 1. Objection. The identification of documents "that tend to support" a specific claim would require a disclosure of the mental impressions and thought processes of counsel and is accordingly protected by the work-product privilege. 1. Objection. The identification of documents "that tend to suppo ifc claim would require a disclosure of the mental impressions and thought procesgets unsel and is accordingly protected by the work-product privilege. Invoices reflecting expenses incurred in defense of this: lawsuit are available for inspection and copying at the offices of at any mutually convenient time determined by prior arrangement. X 6. The only responsive documen naNir - the original and amendej Dimple nts in this action - Epstein's Motion to ,Depdse Rothstein (with attachments and certificate of service) filed at the RItA - bankruptcy proceedings - bankruptcy filings and hearing transcripts all of which are already in the ion of Epstein and his counsel nvoices reflecting expenses incurred in defense of this lawsuit are available for inspection and copying at the offices of tine determined by prior arrangement. IMcounsel at any mutually convenient - adrilissible evidence; privileged pursuant to law - 9. Responsive documents are available for inspection and copying at the offices of IIMcounsel at any mutually convenient time determined by prior arrangement. - 10. None - 11. Objection. Overly broad, not reasonably calculated to lead taiitare.discovery of ' - M right and; i'rig of his clients, . 0 . partners, and associates to economic privacy, and in so Crcurristances subject to contractual confidentiality provisions. - 12. None - 13. Records reflecting the amount of has been obliged to devote to the defense of Epstein's ma busive, and baseless legal actions against are available for intatti d copying at the offices of counsel at any mutually convenkacliple determined by prior arrangement. - 14. None - 15. Records .rettecting the amount of time which has been obliged to devote to th &tense' of Epstein's malicious, abusive, and baseless legal actions against available for inspection and copying at the offices of utually convenient time determined by prior arrangement. - 16. Objection. Attorney work product privilege - 17. Objection. Attorney work product privilege MO adv. Epstein Case No.: 502009CA040800XXXXMBAG Plaintiff(s) Response to Request to Produce adv. Epstein Case No.: 502009CA040800)OOO(MBAG Plaintiff(s) Response to Request to Produce 18. Objection. Overly broad, not reasonably calculated to lead to the discovery of admissible evidence, privileged pursuant to right and the rights of his clients, law partners, and associates to economic privacy, and in some circumstanc subject to contractual confidentiality provisions. 01. Objection. Attorney work product privilege except to A\`C is identified as a source of information in published k en available to Jeffrey Epstein as to through inti4 \*Arches. that ich are as easily 01. None the 22. None except to the extent that rtdltj Victims Rights Act proceedings fall within description of this request. Plead' hf matter are public records readily available to Jeffrey Epstein. 21. None 01. See Edwa sir Motion for Summary Judgment and attachments thereto and all pleadings and filings in the state and federal criminal proceedings against Epstein and in each of the civikaaims brought against and settled by him—all of which are already in the possessiortottpstein and/or the members of the various law firms who do and have represented hitt'. • [REDACTED] adv. Epstein\ Case No.: 502009CA040800XXXXMBAG\ Plaintiff(s) Response to Request to Produce I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by\ Fax and U.S. Mail to all Counsel on the attached list, this 6th day of January, 2012. ![](<>)Jack Scarola\ Florida Bar No.: 169440\ Searcy Denney Scarola Barnhart & Shipley, P.A.\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach, Florida 33409\ Phone: (561) 686-6300\ Fax: (561) 383-9451\ Attorney for [REDACTED] J: [REDACTED] Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Plaintiff(s) Response to Request to Produce ## COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 Fanner, Jaffe, Weissing, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Marc S. Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556 L. Ackerman, Jr., Esq Burnett, P.A. 901 Point West 777 S Flagler Drive West Palm Beach, L 33 -6170 Phone: (561) 8 4 Fax: (561) 8 # EXHIBIT D NOT A CERTIFIED COPY ### Tina L. Campbell From: Tina L Sent: Wednesday, January 17, 2018 7:17 AM To: Chris R. Rod ers Subject: E stein v. Attachments: 2011-4-7 Telephone Interview.pdf Hi Chris, Could you please send me the audio for this telephone interview? Thank you. ![](_page_50_Picture_14.jpeg) Tina... CP/FRP CO Cerlili ara ega LINK & ROCKENBACH, PA 1555 Palm Beach Lakes BI 01 West Palm Beach, FL 3340 office (561) 727-36001 fax (561) 727-3601 I Email: tinagNinkrocklaw.com This e-mail may contain privileged or confidential Information. If it is not meant for you, please delete It and notify us immediately. Please confirm receipt of time sensitive communications because email deliveries may be delayed or unsuccessful. We do not provide tax advice. Our communications may not be relied upon to avoid penalties that may b sed by the Internal Revenue Service. # **EXHIBIT E** NOT A CERTIFIED COPY ### IN THE CIRCUIT COURT QF THE: FIFTEENTH JUDICIAL CIRCUIT; IN AND FOR PALM BEACH • COUNTY, FLORIDA CASENO:: 502009CA04080.0XXXXMBAG JEFFREY EPSTEIN, VS. SCOTT ROTHSTEIN, individually, J. ineividually, and L.M., individually, Defendants, CO SA COUNTER-PLAINTIFF'S BRADLEY J. SECOND AMENDED EXHIBIT LIST cows NOW the Counter- RADLEY J.:EDWARDS and hereby files his. Amended Exhibit List as follows: - 0. No objection - 1. All objections •2. All objecp e t authenticity - 3. Irrelev aterial - 4. So value substantially outweighed by \*get' of unfair prejudice; confusi0n.of issues, misleading the jury, or 'needless presentation of cumulative evidence - 5. Privileged - 6. Opinion - 7. Hearsay - 8. Authenticity lacking - 9. Other (please identify basis of objection) ### BJE ONS Jeffrey Epstein vs. Scott Rothstein, J. and L.M. Case No. 502009CA040800XXX X BA, Counter-Plaintiff's, List J. Second Amended Exhibit Counter-Plaintiff No. Marked Marked for Objection in Evidence Identification Description of Exhibit | 1. 2. | All applicable criminal statutes. All applicable Florida Statutes. | | | | -------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --- | --- | | 3. | Photos and information of Jeffrey Epstein's homes, airplanes and automobiles. | 4 | 1 | | 4. | Order confirmation from Amazon.com for purchase of books SM 101: A Realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude-Principles, Skills and Tools" and "Training Miss Abernathy: | | | | | A Workbook for Erotic Slaves and Their rs | | | | 5. | Non-Prosecution Agreement. :\\ Jane Doe 102 Complaint. t' | | | | | Messages taken from mes e pa found at Epstein's home. | | | | 8. | Documents related to Jeffrey Epstein produced by Alfredo Rodriguez. | | | | 9. | Jeffrey Epstein's flight logs. | | | | 10. | Jeffrey Epstein's phone records. | | | | 11. phone records. 1 | | | | | 1 -\\ | tafl Visitation Logs. Jeffrey Epstein's probation file. | | | | 14. | All probable cause affidavits related to criminal investigation of Jeffrey Epstein. | | | | 15. | Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein. | | | | 16. | Video of Epstein Property Inspection, 01/18/10. | | | | 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. | home. Complaint Jane Doe v. Epstein and all subsequent Amended Complaints. All records of homes, properties, bank accounts and any/ all records related to Jeffrey Epstein's ACIA assets. Jeffrey Epstein's passport (or copy). CO .' Jeffrey Epstein's driver's license (or copy). List of corporations owned by Jeffrey Epst • c Yearbooks of Jane Doe. 2002 Palm Beach High Sc ht '\\ook. 2001 Palm Beach Hi Near Book. 2003 Palm Beach G chool Year Book. Affidavit and A or Search Warrant on Jeffrey Epste 's h e (from Palm Beach State Attorney's, hibit #29). Note s found in Jeffrey Epstein's home and/or d trash pulls outside of his home during - . in vestigation. | | ----------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 29. | 1 aim Beach State Attorney's Criminal file ainst Jeffrey Epstein. | | 30. | All documents related to Jeffrey Epstein's 6/30/08 conviction. | | 31. | Jeffrey Epstein's criminal plea colloquy. | | 32. | List of properties and vehicles in Larry Visoski's name. | | 33. | All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and in cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092. | | | | | --- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --- | --- | --- | | 34. | All discovery related responses of Jeffrey Epstein in this matter and in cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092. | | | | | 35. | Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him. | | | | | 36. | All Complaints in which Jeffrey Epstein is/was a defendant. | | | | | 37. | Jeffrey Epstein's Deposition testimony and discovery responses in this case and in cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092. | | | | | 38. | Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXIMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB. | | | | | 39. | Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No 502009CA040800XXXXMBAG. | | | | | 40. | Any and all newspaper articles, online articles or publications related to Jeffrey Epstein. | | | | | 41. | Report and Analysis of Jeffrey Epstein's assets. | | | | | 42. | Video footage (DVD) of walk through site | | ------------ | ---------------------------------------------------------- | | 43. | Photos of all of Jeffrey Epstein's properties, cars, boats | | 44. | Probable Cause Affidavits DreDared against | | | Jeffrey Epstein and Alik' | | 45. | Documents related to or evidencing Jeffrey | | | Epstein's donations to law enforcement. CP S | | 46. | Victim Notification Letter from US Nils, | | 47. | Expert Dr. L. Dennison Report 1 | | | ik lir | | 49. | All reports and documentation generated by Palm | | 50. | All Witness Statements generated by Palm | | 51. | Passenger Manifests of Jeffrey Epstein's aircraft | | 52. | singer lists for flights taken by Jeffrey Epstein. | | 54. | Jeffrey Epstein's bank statements. | | 55. | Jeffrey Epstein's tax returns. | | \_\_\_\_\_\_\_\_ 56. | ,4:fi2:= volving co | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009CA040800XXXXMBAG Counter-Plaint" Ms, I M, Second Amended Exhibit List | | uat, Jean Luc Brunel and | | --- | ----------------------------------------------------- | | 57. | DVD of plea and colloquy taken on 6-30-08. | | 58. | Transcript of plea and colloquy taken on 6-30-08. | | 59. | Palm Beach Police Department Incident Report dated | | | 07/25/06 (unredacted) 40441.8' | | 60. | No Contact Orders entered against Jeffrey Epstein. N" | | 61. | Criminal Score Sheet regarding Jeffrey Epstein. | | 62. | Documents evidencing Jeffrey Epstein's Corn | | 63. | Jeffrey Epstein's Sex Offender Registratibisr m | | 64. | Jeffrey Epstein's Booking pho p | | 65. | CAD calls to 358 EL B ZY, | | 66. | List of Jeffrey E teinphiuse contacts. | | 67. | Documents related to Jeffrey Epstein's investments. | | 68. | Letter from | | 70- | '1.etter | | | from to | | 71. | Letter from to | Jeffrey Epstein vs. Scott Rothstein, and L.M.. Case No.: 5020091.100XXXXMBAG Counter-Plaineff's, J Second Amended Exhibit List | 72. | Letter fro | to | | --- | ------------------------ | ------------------------------------------- | | 73. | Letter fro | to | | 74. | Letter fro | to | | | Assistant Assist | e orney, | | | | 404 A' | | | | Letter from Goldberger, 06/22/06. %Id | | 76. | | All subpoenas issued to State Grand Jury. c | | 77. | aL | ments related to the rental of a ye | | 78. | Ted's Sheds Documents. | | | 79. | Documents related to pro | es of | | | | Jeffrey Epstein's propertiQ , | | 80. | | Arrest Warrant of Sarah Kellen. | | 81. | Police report regarding | picking | | 82. | Lis | Trilateral Commission Members of 2003. | | 83. | Ala | ershowitz Letter dated 04/19/06 and Statute | | 84 | | tter dated 04/17/06. | | 85. | | Jeffrey Epstein Account Information. | | 86. | | Jeffrey Epstein Criminal Closeout Sheet. | | 87. | | JEGE, Inc. Passenger Manifest. | | 88. | Hyperion Air Passenger Manifest. | | ---- | ---------------------------------------------- | | 89. | Flight information for | | 90. | Passenger List Palm Beach flights 2005. | | 91. | Jeffrey Epstein notepad notes, re: Maria. | | 92. | Pleadings of Jane Doe 1 and 2 v. US case. | | | 404 A | | 93. | Jeffrey Epstein 5t^ Amendment Speech. IC:) 4 | | 94. | Reiter letter to Krisher, 05/01/06. C .( | | 95. | Police Report, 11/28/04. | | 96. | Victim's school records and transcripts. | | 97. | Victim Notification letter t 09/03/08 | | 98. | Police report of Juan Alessi e t J y Epstein's | | 99. | Victim's Medical R Dr. Randee Speciale. | | 100. | All surveillance ondu t d by law | | | enforcement on Epstein's home. | | 101. | Emails re c rom Palm Beach Records | | | rel to Je y Epstein. | | 102. | et em listed on the Palm Beach Police Property | | | rt, Lists and/or Property Receipts. | | 104. | Jeffrey Epstein criminal records. | | 105. | All documents produced by Palm Beach Police | | 106. | Statements, deposition transcripts, videotaped | | ---- | -------------------------------------------------- | | 107. | Any and all expert witness reports and/or records | | | party to this cause. AeAsk | | 108. | Demonstrative aids and exhibits including, but not | | 109. | reserves all objections to Epstein' | | 110. | reserves the right to supplem | | 111. | By listing an Exhibit, Edward no ving | | | his right to object to same at a oes not | | | waive their right to ame e. | | 112. | All exhibits listed subject to | | 113. | All pleadi and a chments in the action | | | under the ictims Rights Act prosecuted | | | by B ley wards on behalf of victims of | | | E 's criminal molestations. | | | Ed s' Motions for Summary Judgment, all | | 115. | All time records and hourly billing | | 116. | All deposition testimony and discovery responses | | 117. | All pleadings filed by Epstein in the | | ---- | ---------------------------------------------------- | | 118. | All submissions by Epstein in connection with | | 119. | All Settlement Agreements between Epstein | | | and victims of his sexual molestations. Arnik' | | 120. | Phone Journal taken from Epstein's home and produced | | 121. | Photo depicting Ghislaine Maxwell | | 122. | All flight logs for any Jeffrey Epstein o | | 123. | AcN, | | 124. | Evidence of contributions to the Palm Beach Police | | 125. | Dr. Bernard J. Jansen Expert Report, Attachments and | | 126. | Jeffrey Epstein vs. Scott Rothstein, J. | | | e‘y Epstein vs. Scott Rothstein, J. | | 128. | Jeffrey Epstein vs. Scott Rothstein, J. | | | Defendant/Counter-Plaintiff Fourth | | 129. | Jeffrey Epstein vs. Scott Rothstein, J. | | ---------------------- | ------------------------------------------------------ | | 130. | Brad Edward's Times Records and Billing Records | | 131. | Epstein's NY State Online Sex Offender | | 132. | New York Post article: Billionaire Jeffrey Epstein: l' | | Mat | New York Presbyterian Ho | | 134. | Hand Drawing of Bart Simpson (sign | | 135. | Proposed Joint Letter to the S ml r. | | 136. | Front and Back of Hard Col Phot' | | 137. Color photo o | ferry "New York". | | 138. Scenic photo of i | Square. | | 139. | hoto on back of ship. | | 140. | room in New York. | | r | , | | 141. | photo of man on horse (New Mexico Ranch). | | 142. Color photo of | at Zorro Ranch | | 143. | photo on horse front of ranch. | | 144. | photo standing against rocks (red | | 145. | standing against rocks (red coat) (far) | | ---- | ------------------------------------------------- | | | (with back photo = back date). | | 146. | photo riding horse blue jacket far. | | 147. | photo on side of horse hand up. | | 148. | photo on side of horse. S ic | | 149. | photo outside next to tables. | | 150. | photo red coat leaning on rail. | | 151. | photo standing outside next to fireplace. | | 152. | photo standing in front of ranch. | | 153. | photo with hand over head | | 154. | photo standing next to piano. | | 155. | photo in front of fireplace (museum). | | 156. | photo in front of wagon in museum. | | 157. | Color photo of in front of museum | | 158. | Photograph in Spain Jeffrey Epstein and Ghislaine | | 159. | ANS (Australia Storage): Photo Book 2. | | 160. | Cover photo book 2. | | 161. | Scenic photo (with back photo. | | 162. | Scenic photo (with back photo IM). | | 163. | Scenic photo (with back photo P. | | 164. | Scenic photo (with back photo M). | | ---- | -------------------------------------------------- | | 165. | steps with trees overhead. | | 166. | Scenic photo (with back photo M. | | 167. | Scenic photo (with back photo M). | | 168. | Scenic photo (with back photo In. | | 169. | Scenic photo (with back photo M. | | 170. | Scenic photo (with back photo and black). | | 171. | Scenic photo (with back photo and blac .• | | 172. | Scenic photo (with back photo an | | 173. | on steps with child ack photo | | 174. | on street ' I (far) (with back | | | photo and black). | | 175. | Travel envelope. | | 176. | Si • ; is. t a • i el Cover with handwritten notes | | 177. | Thand Hotel Receipts. | | | o Docket for Jane Doe No. 102 v. Epstein. | | Ac | t rivestigation | | 180. | Ghislaine Maxwell deposition, 04/22/16 | | 181. | FBI Form 302 - Interview of in | | 182. | Mark Epstein Deposition. | | 183. | March 19, 2008, email of Assistant U.S. Attorney Ann [REDACTED] (Summary of the Case) (Coonan File). | | | | | ---- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------- | --- | --- | --- | | 184. | Color photos of Ghislaine Maxwell, one with Jeffrey Epstein. | | | | | 185. | Airport Codes ( Demonstrative ). | | | | | 186. | March 3, 2011 - New York Post: Uppity Tranny to Epstein: Pay Up! | | | | | 187. | DVD of Epstein PBPD 358 El Brillo Search Warrant Walk Through 05/11/09; DVD Audio from Cassettes, Part 1. | | | | | 188. | [REDACTED] Redacted Transcript taken by Detective Joe [REDACTED] and Detective Dawson (with Exhibits) 10/11/05. | | | | | 189. | Palm Beach Police Investigation: Palm Beach PD Records; Wachovia Bank Account. | | | | | 190. | Folder title [REDACTED] Cell Phone Summary by [REDACTED] Enclosing phone records. SAO FOIA Disc 7 (State Files). | | | | | 191. | Folder title [REDACTED] Cell [REDACTED] Cell Phone Usage 09/2005-10/2005. | | | | | 192. | Folder title \[REDACTED\]: AT&T February 12, 2005 Statement. | | | | | 193. | Demand Deposit Account Statement History for Household Bank Account Jeffrey Epstein or Ghislaine Maxwell or Alfredo Rodriguez. | | | | | 194. | Santa Monica Police Report (May 12, 1997). | | | | | 195. | Folder titled PLANES: Information relating to Epstein's planes/aircrafts collected by the State Attorney's Office unique to the investigation of Jeffrey Epstein. | | | | | 196. | Palm Beach House/Information Sheet. | | ---- | --------------------------------------------------------- | | 197. | Sworn Statement of Juan Alessi taken by Palm Beach | | 198. | Juan Alessi Deposition (Vol. I) 09/08/09. | | 199. | Juan Alessi Deposition (Vol 11) 09/08/09. d ic | | 200. | Brochure for Boeing Super 727-100. | | | 0 201. Passport application; issued January 12, 2001. ) 1 | | 202. | Sentencing Transcript, Alfredo Rodriguez. | | 203. | Criminal Complaint —Alfredo Rodriguez. ,S ) | | 204. | Plea Agreement — Alfredo Rodriguez. ", | | 205. | Photos of Jeffrey Epstein's properties and planes. | | 206. | Photos of Jeffrey Epstein employees and former | | 207. | Jeffrey Epstein Guilty Plea documents. | | 208. | Palm Beach County State Attorney's Response to Public | | | Records Request (including audio recordings). | | 209. | Any and all responses to Subpoenas Duces Tecum with | | | opk ..r | | 210. | AC | | 211. | Any and all documents produced in this action. | | 212. | Any and all depositions taken in this action. | | 213. | Any documents or other exhibit attached to or used | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M..\ Case No.: 502009CA040800XXXXMBAG\ Counter-Plaintiff's, [REDACTED] J. [REDACTED] Second Amended Exhibit List | 214. | Any and all exhibits, documents, etc. referred to in any deposition. | | | | | ---- | -------------------------------------------------------------------------------------------------------- | --- | --- | --- | | 215. | Any and all documents and exhibits designated by all parties to this action. | | | | | 216. | Any and all exhibits needed for impeachment or rebuttal. | | | | | 217. | Any and all pleadings filed in this action. | | | | | 218. | Any and all records produced or that will be produced by all records custodians relative to this action. | | | | I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 7th day of December, 2017. ![](<>)Jack Scarola\ Florida Bar No.: 169440\ Attorney E-Mail(s): jsx@searcylaw.com and\ mep@searcylaw.com\ Primary E-Mail: \_scarolateam@searcylaw.com\ Searcy Denney Scarola Barnhart & Shipley, P.A.\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach, Florida 33409\ Phone: (561) 686-6300\ Fax: (561) 383-9451\ Attorneys for [REDACTED] J. [REDACTED] Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M..\ Case No.: 502009CA040800XXXXMBAG\ Counter-Plaintiff's, [REDACTED] J [REDACTED]. Second Amended Exhibit List **COUNSEL LIST** Jack Scarola, Esquire\ scarolateam@searcylaw.com;\ Searcy Denney Scarola Barnhart & Shipley PA\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach, FL 33409\ Phone: (561) 686-6300\ Fax: (561) 383-9451\ Attorneys for [REDACTED] J. [REDACTED] Scott J. Link, Esq.\ Link & Rockenbach, P.A.\ Scott@linkrocklaw.com\ Kara@linkrocklaw.com\ 1555 Palm Beach Lakes Boulevard, Suite 301\ West Palm Beach, FL 33401\ Phone: 561-727-3600\ Fax: 561-727-3601\ Attorneys for Jeffrey Epstein William Chester [REDACTED], Esquire\ wcblaw@aol.com; wcblawasst@gmail.com\ 250 S Australian Avenue, Suite 1400\ West Palm Beach, FL 33401\ Phone: (561)-655-4777\ Fax: (561)-835-8691\ Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire\ jgoldberger@agwpa.com; smahoney@agwpa.com\ Atterbury Goldberger & Weiss, P.A.\ 250 Australian Avenue S, Suite 1400\ West Palm Beach, FL 33401\ Phone: (561)-659-8300\ Fax: (561)-835-8691\ Attorneys for Jeffrey Epstein Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009 hc.gargiaaaMBAG Counter-Plaintiff's, J Second Amended Exhibit List J. , Esquire alle®pathtojusti Jaffe WeissingilinFistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Alk " ,1O Tonja Haddad Coleman, Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 C O efiling®tonjahaddad.com Attorneys for Jeffrey Epstein Phone: (954)467-1223 Fax: (954)-337-3716 iS 5) Marc S. Nurik, Esquire marc@nuriklaw.com One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein c ?S'